Insurance Self-Network Platform: post-registration Compliances

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Insurance Self-Network Platform: post-registration Compliances

After successfully registering your Insurance Self-Network Platform, you are expected to follow some of India's IRDAI (Insurance Regulatory and Development Authority) post-registration compliances. These compliances are expected to be adhered to by the ISNP registration license holder for their proper functioning and operation in the insurance market. Any violations of these compliances might invite disciplinary actions from the IRDAI. So, for the smooth functioning of your e-commerce initiative to provide insurance-related services, you must adhere to these compliances. This adherence will help you in the renewal process of your ISNP license. Here, we discuss some of the compliances to be followed by a newly registered ISNP license holder.

Online Presence

• The registered ISNP must make themselves accessible via a regular internet website and/or a mobile application. 

• The ISNP must enroll only registered insurers operating in the market. These insurers must possess a certificate of registration granted by the Authority.

• Suppose the Insurance Self-Network Platform has enrolled any unregistered market insurer. In that case, it will be viewed as a very serious violation of the ISNP code of conduct, which may even lead to the cancellation of the permit issued by the Authority.

Information declaration on the Website (Mobile App)

The Insurance Self-Network Platform website must display the following information about itself on its website at all times: 

• Registered name

• Address

• Telephone and e-Contact information 

• Certificate of Registration Number

• Incorporation certificate validity

• Category of certificate of registration 

• Information on the procedure for filing a complaint by a policyholder. This must also include a link to the Authority's website. 

• Any other relevant information. 

Disclosure of Insurance products information

• Only Product Approval terms approved products must be displayed on the Insurance Self-Network Platform website.

• Any information that misinforms the policyholder and is harmful to them and/or not approved by the Authority is prohibited from being displayed on the ISNP website.

• Insurance-related products on the ISNP website must be up to date and reflect the absolute true picture of the service(s) being offered.

• The ISNP of a registered insurer must not display products of other registered insurers except in the case of a combination of insurance products with other insurers. 

• The ISNP of a registered insurance intermediary must not make any promise or commitment to insurers for the sale of their products and also not favor any one insurer of his or her choice. 

Pre-sale Solicitation

The registered Insurance Self-Network Platform must provide details of procedures, processes, and timelines for pre-sales solicitation of insurance policies.

lnformation Sharing

The registered ISNP offering insurance products online shall bring the prospect's attention to the following information: 

• The type of consumer for whom the product is intended;

• Main characteristics of the product;

• Options and coverage provided by the product;

• Exclusions and limitations associated with the product; 

• Premium and other charges payable by the consumer 

• The prospect's right to cancel' if applicable, as well as the duration of the cancellation period and procedures for exercising that right; 

• Any time limit on the validity of the information provided. 

Insurance Products 

• If no changes are reflected in the terms & conditions, benefits, exclusions, pricing, including discounts, etc., of the insurance products, then refilling of insurance products will not be necessary.

• If some necessary changes are made in any of the mentioned insurance product(s) or if the insurer has introduced a new product, then, in that case, the Product Approval terms shall be followed. 

• All products shall be sold in e-form format under the IRDAI (issuance of e-insurance policies) Regulations of 2016. 

• All the products of an insurer that he/she desires to display on an ISNP must be approved under the Product Approval terms. 

• All the products of an insurance intermediary that he/she desires to display on an ISNP must be approved under the applicable regulations. 

Pricing 

• The insurer must decide the price of the product. It is the insurer's responsibility that product pricing complies with the product approved by the Authority. 

• The insurer can offer discounts on its product as specified by the Authority. 

• The differential price for products offered on ISNP of any applicants must be the same.

Here we have discussed some of the compliances that must be observed by a registered ISNP as directed by the IRDA. There is more to it, which will be discussed in the article.

Commissions and Remunerations

• The IRDAI (Payment of commission, remuneration, or reward to insurance agents and
• insurance intermediaries) regulations of 2016 clearly state the guidelines for selling an insurance product on the ISNP website. 
• The ISNP, by themselves, cannot charge any fee, extra charges, or payments other than that allowed by the IRDAI Regulations. 
• The revenue generated by the sales of insurance services and products will be shared between the market participants for utilizing the registered ISNP.

Compliance with KYC/ AML norms

• The registered ISNP must comply with all the directions issued by the Authority for compliance with Know Your Customer (KYC) and Anti-Money Laundering (AML) matters.
• Compliances to the KYC/ AML guidelines must be submitted using 
• e-KYC facility offered by UIDAI
• e-PAN facility offered by NSDL
• Valid KYC documents permitted under Authority's AML
• Any other facility recognized by the Authority

E-insurance Account

• The e-insurance account must be undertaken within 15 days of selling insurance policies on the registered ISNP.

• Every customer must have an email id or a registered mobile phone number while transacting insurance business on the registered ISNP.

Payment of premium

• The online payment of premiums can be facilitated by net banking, e-wallet, credit card, debit card, or any other payment system as permitted by the RBI from time to time.

• The ISNP can also facilitate payment of premiums through cheque/ demand draft.

• The ISNP can also accept cash payments if the insurers come up with a system that gives an immediate confirmation on the policyholder's email address or his mobile phone, affirming the reception of the premium's payment.

• The system of sales of insurance products and reception of premiums facilitated by the ISNP on its platform must not be detrimental to the interests of the policyholders.

e-Insurance policies

• Once the business transaction on the ISNP platform is complete, the next step will be the premium payment. The insurer, on successful payment, must generate the e-premium receipt and send it to the prospect through email immediately.

• The e-insurance policy document must be credited to the policyholder's e-insurance account.

Servicing of Policies

Every registered Insurance Self-Network Platform must provide the details of procedures, processes, and timelines for post-sales servicing of insurance policies for activities.

Securing Personal Information and Data Security

• The details of the transactions on the ISNP web portal, which involve the personal information of the insurers and policyholders, must be kept confidential to prevent them from being misused.

• The registered ISNP must adopt measures to safeguard data privacy and personal information before they kickstart their business operation to prevent the manipulation of records and transactions, thus compromising the privacy and safety of information. 

• The measures taken by the ISNP must be reviewed periodically, and take corrective steps if needed.

Website Display regulations

• A maximum of 80% of the portal of an ISNP platform can be the images, not more than that.

• All the disclaimers regarding the products and services can be clubbed together in one place so that the customers can access all disclaimers together through this single link.

• All the conditions given in the IRDA's (Insurance Advertisement and Disclosures) Regulations of 2015 must be observed.

Grievances management

• A mechanism must be devised to deal with the grievances of the existing customers more expeditiously and effectively. Say, if the premium payment has been done twice, then the one-time payment of the premium must be quickly refunded to the policyholder.

• Any grievance of policyholders must be resolved in a given time frame. The first response to the customer, resolving their problem, and delivering them the remedy must be done in a specified time frame by the ISNP.

• An Integrated Grievance Management System must be set up to manage the grievances put forth by the customers.

Fraud

1. It is the duty of a registered lSNP to have a proactive fraud detection policy to secure its insurance-related e-commerce activities approved by the ISNP's Board of Directors.
2. The Fraud detection policy must include the following clauses:

• • The procedure of fraud detection and identification of the culprit.
  • Follow-up mechanism for prosecuting fraudsters.
  • Establishing cooperation mechanisms amongst market participants to identify frauds of all kinds, especially those rampant in today's market.
  • Recording the committed frauds in a database for further reference for other Market participants.

Record maintenance

Every marketing participant on the ISNP platform must maintain sales and distribution records of insurance products and services as per the regulations set by the Authority.

Standard Operating Procedure 

• A standard operating procedure must be followed by the registered ISNP for both its lT and non-lT processes, and the ISNP must keep the same ready for inspection by the Authority at all times. 
• If needed, an updated version can also be maintained by the said ISNP and must be kept ready in case of an inspection authorized by the Authority. 
• Suppose non-compliance on th part of the firm is inspected, seeing a clear deviation from the SOP. In that case, such violation will be taken seriously and, in worse cases, can invite penal action on the part of the Authority.

Other related compliances 

The CEO and the compliance officer of the registered Insurance Self-Network Platform must submit an annual compliance certificate to the IRDAI, signaling that the information displayed on the ISNP web portal complies with the guidelines at all times issued by the Authority.

Other issues 

The applicant shall immediately report to the Authority any regulatory or supervisory action was taken by any Government or other Regulatory Authorities with full details and the penalty, any administrative action, if any, imposed and the remedial steps were taken by it to prevent its recurrence concerning the ISNP.

Reporting

The ISNP must submit the reports asked by the Authority as and when required.

More IRDAI and Govt regulations

• The Authority shall have the right to call, inspect or investigate any document, record or communication from the applicant's ISNP.
• Notwithstanding the above, where the Authority is of the opinion that the operations of the applicant's ISNP are not in the interests of the Indian market or
• the insurance policyholders, the Authority reserves the right to take appropriate steps, including suspension or cancellation of permission granted.
• Power of the Authority to issue clarifications: ln order to remove any difficulties in respect of the application or interpretation of any of the provisions of these Guidelines, the Chairperson of the Authority may issue appropriate clarifications from time to time

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