AM Best Assigns Performance Assessment to Castel Underwriting Agencies Limited, Castel Underwriting Europe B.V.

By Favour Nnabugwu

 

AM Best has assigned a Performance Assessment of PA-2 (Excellent) to Castel Underwriting Agencies Limited (Castel) (United Kingdom) and Castel Underwriting Europe B.V. (CUE) (Netherlands).

CUE is a wholly owned subsidiary of Castel. The outlook assigned to the Performance Assessment (assessment) is stable.

This assessment reflects Castel’s excellent underwriting capabilities, excellent governance and internal controls, excellent financial condition, excellent organisational talent and excellent depth and breadth of relationships.

In AM Best’s view, CUE’s operations exhibit a number of commonalities with Castel and CUE is regarded as strategically and financially important as the group’s European platform, providing access to business in the European Economic Area. CUE is integrated with Castel and has common underwriting practices, with generally consistent underwriting performance expected.

Castel, through its model of investing in early-stage managing general agents (MGA) and underwriting teams (collectively “underwriting cells”) on its club-style MGA platform, has access to expert and experienced underwriters with a proven track record in their niche. Underwriting capabilities further benefit from Castel’s in-house underwriting staff. Since launching in 2014, Castel has demonstrated its ability to grow its underwriting cells whilst providing profitable business to its capacity providers. The limited track record of a number of Castel’s programmes is considered a partially offsetting factor to the underwriting capabilities component.

Castel’s governance and internal controls benefit from its scale, relative to many other delegated underwriting authority enterprises (DUAEs) in the market. The company has an appropriate committee structure, including a board of directors featuring independent and non-executive directors, supported by a number of other committees. The company performs internal reviews regularly, covering underwriting and compliance. There is limited integration of systems with (re)insurance partners.

Castel’s financial condition is supported by its consistently profitable operations since inception. Stability of income benefits from the broad range of programmes underwritten by the company, reducing dependence on any single programme. AM Best considers the acquisitive nature of Castel’s business model to pose some risks to the company’s financial condition. The company is aware of and actively manages these risks.

Castel’s senior management team is experienced and has a proven track record in the industry. The company’s board of directors brings further experience and oversight. The organisational structure is well-defined with a clear path of reporting duties.

Castel offers a range of programmes in its core markets in the United Kingdom and Europe, as well as internationally. The company has relationships with a high number of well-rated capacity providers. A significant portion of Castel’s processed premium is placed with capacity providers that have supported Castel for at least three years.

Insurance can help countries achieve UNSDGS – Naicom

By Favour Nnabugwu

 

The Commissioner for Insurance/CEO, National Insurance Commission (NAICOM), has said that insurance can can help countries achieve United Nation’s Sustainable Development Goals (UN SDGs)

In his opening remarks at the Declaration on insurance conference in Lagos yesterday, Olorundare Sunday Thomas, NAICOM boss said the conference has brought together stakeholders in the African insurance market to deliberate on modalities to facilitate attainment of a sustainable future.

Thomas explained that the conference also aims to explore ways that insurance can play a significant role in helping African countries achieve the United Nation’s Sustainable Development Goals (UN SDGs) in terms of economic growth, social inclusion, and environmental protection and ensure sustainable development in the African insurance sector.

He said “We are indeed grateful to our development partners, the Financial Sector Deepening Africa (FSD Africa), UK Aid and the United Nations Environmental Program for the invaluable support.

It would appear that the role of insurance has been somewhat relegated within the context of the SDGs. This is because the current indicators largely do not capture specific insurance related metrics. To be able to better assess the role of insurance and motivate the industry to contribute more to the SDGs, more consistent and disaggregated data collection is recommended.

It is, however, an acknowledged fact that the insurance industry performs a very critical role in promoting economic, social and environmental sustainability and can help countries achieve the UN SDGs.

The insurance industry helps protect society through risk prevention, risk reduction and risk sharing. The industry therefore plays an important role in nine (9) of the Sustainable Development Goals (SDGs) namely: No Poverty, Reduced Inequalities, Zero Hunger, Good Health and Well-Being, Gender Equality, Decent Work and Economic Growth, Industry Innovation and Infrastructure, Climate Change, and Partnerships for Goals.

In addition, the insurance industry also plays an indirect and supporting role in five of the SDGs, namely: Quality Education, Industry Innovation and Infrastructure, Reduced Inequalities, and Partnerships for Goals and Sustainable Cities and Communities.
Therefore, the insurance sector holds the potential for enhancing sustainable development with the 2030 Agenda.

Environmental, social and governance (ESG) issues constitute a shared risk to insurers, businesses, governments and society. Some ESG issues such as, climate change, pollution and eco-system degradation, have various ramifications. Some of these issues are now considered as likely to be financially material to the success of organizations. There is therefore the compelling need for innovation and collaboration.

The four (4) Principles for Sustainable Insurance formalize the commitment of the signatories to ensuring decision-making along ESG criteria; raising awareness with clients and partners on ESG criteria; collaboration with governments and regulators to promote action on ESG criteria; and accountability and transparency of progress in ESG implementation. The corresponding list of possible actions provide a common anchor and framework for the insurance industry to manage ESG issues. This is expected to enhance the industry’s contribution to building resilient, inclusive and sustainable communities and economies.

On the regulatory side, the current environment is increasingly becoming complex. This has heightened the need to ensure effective supervision as well as resolve broader policy challenges such as inclusive economic development, sustainability, climate risk and digitalization. Insurance regulators, therefore, have a vital role to play in sustainable economic development.

Through regulatory and policy initiatives, regulators can guarantee that their insurance jurisdictions offer the essential range and variety of products and services that support the SDGs. Supervisors can also act as conveners of key stakeholders to building partnerships to coordinate insurance solutions, especially when faced with multifaceted risks such as climate change and pandemic risk.

NCRIB mourns train attack on victims

By Favour Nnabugwu

 

The Nigerian Council of Registered Insurance Brokers, NCRIB, has expressed the Brokers condolence with the victims of the deadly attack on unsuspecting passengers of the Nigerian Railway Corporation Train facility from Abuja connecting a regional hub in the North.

In a condolence letter to the Honourable Minister of Transportation, Rotimi Amaechi, the President of the Council, Mr. Rotimi Edu, mni, noted that the council identified with the Federal Government and the immediate family members of the victims, at this moment of grief. President Edu described the attack on the Kaduna bound train with over 900 passengers as unwarranted and hand work of cowards and urged the Federal Government to ensure that the perpetrators of the dastardly act were fished out and made to face the wrath of law to serve as deterrent to others who may have such devilish mind.

Mr. Edu noted that the increasing cases of attack and insecurity in Nigeria constituted a huge challenge to government, foreign investors and other stakeholders and urged all the Services Chiefs to ensure a better synergy to adequately secure lives and properties of Nigerians.

In spite of the strident efforts of the Federal Government through its various dedicated agencies, especially, Ministry of Transportation to build enduring legacies of massive infrastructural development, he said the incidences of gunmen attack and other vices of insecurity remain a blemish that could plunge the nation back into stone ages of poor infrastructure While commending the Kaduna State Government’s directives to bear the cost of treatment of the victims, Mr. Edu seized the opportunity to underscore the need for insurance.

He specifically highlighted the crucial roles of Insurance Brokers who he noted were professional intermediaries in the insurance value chain and have the duty to advise clients about what to insure, how to insure and how to pursue their claims in the event of losses.

CFI, Sunday Thomas speech @ Declaration on insurance confab in Lagos

OPENING REMARKS BY MR O. S. THOMAS, THE COMMISSIONER FOR INSURANCE (NIGERIA) AT THE DECLARATION ON INSURANCE CONFERENCE AT FOUR POINTS BY SHERATON, VICTORIA ISLAND, LAGOS, HELD ON 31ST MARCH 2022

Protocol.

I am pleased to welcome you to this conference on sustainable insurance. This conference has brought together stakeholders in the African insurance market to deliberate on modalities to facilitate attainment of a sustainable future.

We are indeed grateful to our development partners, the Financial Sector Deepening Africa (FSD Africa), UK Aid and the United Nations Environmental Program for the invaluable support.

This conference also aims to explore ways that insurance can play a significant role in helping African countries achieve the United Nation’s Sustainable Development Goals (UN SDGs) in terms of economic growth, social inclusion, and environmental protection and ensure sustainable development in the African insurance sector.

It would appear that the role of insurance has been somewhat relegated within the context of the SDGs. This is because the current indicators largely do not capture specific insurance related metrics. To be able to better assess the role of insurance and motivate the industry to contribute more to the SDGs, more consistent and disaggregated data collection is recommended.

It is, however, an acknowledged fact that the insurance industry performs a very critical role in promoting economic, social and environmental sustainability and can help countries achieve the UN SDGs. The insurance industry helps protect society through risk prevention, risk reduction and risk sharing. The industry therefore plays an important role in nine (9) of the Sustainable Development Goals (SDGs) namely: No Poverty; Reduced Inequalities; Zero Hunger
Good Health and Well-Being; Gender Equality; Decent Work and Economic Growth
Industry Innovation and Infrastructure; Climate Change, and Partnerships for Goals.
In addition, the insurance industry also plays an indirect and supporting role in five of the SDGs, namely: Quality Education; Industry; Innovation and Infrastructure; Reduced inequalities, and Partnerships for Goals and Sustainable Cities and Communities
Therefore, the insurance sector holds the potential for enhancing sustainable development with the 2030 Agenda.

Environmental, social and governance (ESG) issues constitute a shared risk to insurers, businesses, governments and society. Some ESG issues such as, climate change, pollution and eco-system degradation, have various ramifications. Some of these issues are now considered as likely to be financially material to the success of organizations. There is therefore the compelling need for innovation and collaboration.

The four (4) Principles for Sustainable Insurance formalize the commitment of the signatories to ensuring decision-making along ESG criteria; raising awareness with clients and partners on ESG criteria; collaboration with governments and regulators to promote action on ESG criteria; and accountability and transparency of progress in ESG implementation.

The corresponding list of possible actions provide a common anchor and framework for the insurance industry to manage ESG issues. This is expected to enhance the industry’s contribution to building resilient, inclusive and sustainable communities and economies.

On the regulatory side, the current environment is increasingly becoming complex. This has heightened the need to ensure effective supervision as well as resolve broader policy challenges such as inclusive economic development, sustainability, climate risk and digitalization.

Insurance regulators, therefore, have a vital role to play in sustainable economic development. Through regulatory and policy initiatives, regulators can guarantee that their insurance jurisdictions offer the essential range and variety of products and services that support the SDGs.

Supervisors can also act as conveners of key stakeholders to building partnerships to coordinate insurance solutions, especially when faced with multifaceted risks such as climate change and pandemic risk.

On behalf of the Nigerian insurance industry, I wish to thank you all, once again, for joining us. I also wish you a successful deliberation.

AXA Mansard Insurance Plc declares N0.25 dividend to shareholders

By admin

 

AXA Mansard Plc has announced a dividend payment of N0.25 kobo per 50 kobo ordinary share for the financial year ended 31 December 2021.

This dividend payment will be subject to shareholders’ approval at the Annual General Meeting (AGM) and appropriate withholding tax.

According to the disclosure filed with The Exchange (NGX), shareholders are to ensure their names are registered in the Register of Members by the qualification date of April 28, 2022.

On Thursday, May 12, 2022, the dividend which amounts to N2.25 billion will be disbursed electronically to ordinary shareholders whose names appear on the Register of Members as at Thursday, April 28th 2022, and those who have completed the e-dividend registration and mandated the Registrar to pay their dividends directly into their bank accounts.

The company’s registrar is Datamax Registrars Limited and the e-dividend mandate form can be downloaded or filled online on the registrar’s website.
AXA Mansard Plc has 9,000,000,000 outstanding shares and a market capitalization of N19.44 billion at the time of filing this report. The company’s shares opened trading on the 30th of March, 2022 at N2.16 per share and closed at N2.16 per share.

Ghana Reinsurance opens office in Casablanca, Morrocco

By Favour Nnabugwu

 

The Ghana Reinsurance Company has established its presence in Casablanca, Morocco to serve the African Northern Market.

The new office comes in line with the expansion strategy of the Ghanaian reinsurer in North Africa.

Created in 1972, Ghana Re operates also in Kenya and Cameroon through regional structures. In 2020, the company achieved a 23% turnover increase to 311.56 million GHC (52.968 million USD).

Board Chairman of the company George Otoo had late last year revealed this after a short ceremony of swearing in the newly reconstituted board of the Ghana Reinsurance Company.

With the aim of helping to strengthen the financial sector and mobilizing funds for economic growth, Mr. George Otoo stated that the company is finally ready to strengthen its operations across the continent of Africa.

He said plans are underway to enter the North African Market.
“Work is currently in progress to open a third office in Casablanca, Morocco to serve the northern African regional block” he said.

Ghana Re, has established regional office in Cameroon to cater for the central African Zone and it’s a 100% subsidiary of Re Ghana in Kenya to serve the East African Market, he added.

Concluding on behalf of the board, he pledged to continue to guide management through effective supervision and direction to enhance shareholder values and meet the interest of all relevant stakeholders.

The Deputy finance Minister, John kumah on his part, charged the newly reconstituted board to use the African Continental Free Trade agreement as a tool to expand its frontiers.

He also urged the board to embark on expansionary drive into targeted market in Africa to grow its premium income especially in the face of AFCFTA.

Ghana Re is a “home-grown” successful reinsurance company in Ghana with over 48 years’ experience in reinsurance business with a proven track record of providing world-class reinsurance services to local and international markets.

CFI, Sunday Thomas speech at the launch of R3Lab in Lagos

REMARKS BY MR. O. S. THOMAS, COMMISSIONER FOR INSURANCE (NIGERIA) AT THE LAUNCH OF RISK, RESILIENCE AND REGULATORY LAB (R3LAB) LAUNCH, AT FOUR POINTS BY SHERATON, VICTORIA ISLAND, LAGOS ON 30TH MARCH 2022

I am pleased to welcome you to the Launch of the Risk, Resilience and Regulatory Laboratory (R3Lab).

This event was conceived by our development partners, Financial Sector Deepening Africa (FSD Africa) funded by UK Aid. The setting up of the R3Lab was given impetus by our mutual interest in maximizing the untapped potential of the African insurance industry and exploring ways in which collaboration, technology and insurance supervisory capacity building is capable of not only mitigating the impact of specific challenges experienced in the regulatory environment but also improve the regulatory effectiveness of African insurance supervisory authorities.

We are all aware of the evolving risks in the Africa economic space such as climate change, pandemics, digitalization, inadequate understanding and lack of confidence in the insurance sector and the need for new strategies to enhance the capabilities of African insurance supervisory authorities to effectively regulate and protect insurance policyholders.

The R3Lab offers a three-tiered approach towards creating an enabling regulatory environment and equipping the regulator with sound, proportionate and fit-for-purpose practices.

Risk, Resilience, and Regulation are the key entry points for the R3Lab to build the technical capacity and skills of the regulator on innovation and sustainable insurance. The R3Lab will facilitate the design of customized capacity-building programs and set up peer to peer exchange platforms, comprehensive learning toolkits, a resource center for data collection and reporting and topical taskforces and forums for insurance supervisors in Africa.

I am pleased to confirm that this platform is the third joint-initiative that has been birthed through FSD Africa’s partnership with NAICOM. The first was FSD Africa’s ongoing support in the review of existing regulations including identifying and articulating the key steps, framework(s), and tools required by NAICOM for Risk-Based Capital (RBC). This will enable NAICOM fully implement a scalable RBC Framework in Nigeria as well as to help it develop an innovation framework for NAICOM to fulfill its dual objectives of market development and policyholders’ protection.

It is also gratifying to state that, FSD Africa in furtherance of its support to NAICOM and the Nigerian insurance industry, we officially launched the second project, the BimaLab Insurtech Accelerator in February 2022. The platform selects, coaches and mentors insurtech firms, granting these firms access to FSD Africa BimaLab Grant Fund in developing innovative business solutions focusedon solving compelling economic or social problems. I understand ten (10) selected participants are already undergoing 10 (ten) weeks intensive mentorship and coaching. Let me, on behalf of the Management and staff of the National Insurance Commission, express our sincere gratitude to FSD Africa for the invaluable support.

It is my hope that through the commissioning of these projects and platforms, we create an enabling environment for the development of insurance products which address the day-to-day challenges experienced by Nigerians in the face of environmental related risks. Availability of better products is likely to result in better service delivery and increase financial returns to investors. In recognition of this, NAICOM aims to achieve greater public trust and confidence in the insurance sector through “Innovation, Distribution and Effective/Efficient Service Delivery” which has been the cornerstone of our strategic focus and actions.

I wish to conclude my remarks by thanking you all once again for joining us as we mark this new milestone in Africa’s path towards achieving a more resilient insurance sector which will inevitably improve the standard of living of Africans and entrench sustainability in businesses

I thank you for your attention.

FSD Africa, Naicom join hands to move African insurance sector forward

By Favour Nnabugwu

 

The Financial Sector Deepening Africa (FSD Africa) funded by UK Aid in collaboration with the National Insurance Commission (NAICOM) on Wednesday launched an initiative to improve Africa’s insurance industry.

The initiative is the Risk, Resilience and Regulatory Laboratory (R3Lab), launched in Lagos.

The Commissioner for Insurance/CEO, NAICOM,  Mr Sunday Thomas, said that the R3Lab was set up to explore ways in which collaboration, technology and insurance supervisory capacity building can improve regulatory effectiveness of Africa’s insurance industry.

Thomas said that collaboration, technology and insurance supervisory were capable of mitigating the impact of specific challenges experienced in the regulatory environment .

” We are all aware of the evolving risks in the African economic space such as climate change, pandemics, digitalisation, inadequate understanding and lack of confidence in the insurance sector.

“Also, the need for new strategies to enhance the capabilities of African insurance supervisory authorities to effectively regulate and protect insurance policyholders.

“We are all aware of the evolving risks in the Africa economic space such as climate change, pandemics, digitalisation, inadequate understanding and lack of confidence in the insurance sector and the need for new strategies to enhance the capabilities of African insurance supervisory authorities to effectively regulate and protect insurance policyholders,” he said.

Thomas posited that the R3Lab offers a three-tiered approach towards creating an enabling regulatory environment and equipping the regulator with sound, proportionate and fit-for-purpose practices.

Risk, Resilience, and Regulation, he said are the key entry points for the R3Lab to build the technical capacity and skills of the regulator on innovation and sustainable insurance.

According to him, “The R3Lab will facilitate the design of customised capacity-building programs and set up peer to peer exchange platforms, comprehensive learning toolkits, a resource center for data collection and reporting and topical taskforces and forums for insurance supervisors in Africa.”

“I am pleased to confirm that this platform is the third joint-initiative that has been birthed through FSD Africa’s partnership with NAICOM.

“The first was FSD Africa’s ongoing support in the review of existing regulations including identifying and articulating the key steps, framework(s), and tools required by NAICOM for Risk-Based Capital (RBC).

“This will enable NAICOM fully implement a scalable RBC Framework in Nigeria as well as to help it develop an innovation framework for NAICOM to fulfill its dual objectives of market development and policyholders’ protection,” Thomas posited.

Thomas on behalf of the Management and staff of the National Insurance Commission, expressed sincere gratitude to FSD Africa for the invaluable support.

He expressed hope that through the commissioning of these projects and platforms, will create an enabling environment for the development of insurance products which address the day-to-day challenges experienced by Nigerians in the face of environmental related risks.

He maintained that availability of better products is likely to result in better service delivery and increase financial returns to investors, adding that in recognition of this, NAICOM aims to achieve greater public trust and confidence in the insurance sector through “Innovation, Distribution and Effective/Efficient Service Delivery” which has been the cornerstone of its strategic focus and actions

Also, t he Chief Executive Officer, FSD Africa, Mark Napier, stated at the launch of the Risk, Resilience and Regulatory Laboratory (R3Lab) initiative in Lagos, stressing that the firm believes healthy financial markets are the foundation of a fair and thriving economy.

He noted that the firm supports breakthrough ideas that will transform Africa’s financial markets, and deliver programmes where the potential for impact is greatest.

He maintained that Africa can unlock new pathways to prosperity and resilience, while helping the world realise the promise of the Paris Agreement and tackle the dual crises of climate change and biodiversity loss.

“We believe that a financial system that is acceptable, stable and transparent, can also help to create the condition for a fair and sustainable future,” he submitted.

 

Great Nigeria promotes MotorFlex insurance product

By Favour Nnabugwu

 

Great Nigeria Insurance Plc has promotes one of its in-house generic products third motor insurance, MotorFlex Insurance with extended cover

In a press statement made available during stakeholders engagement held at Great Nigeria Insurance Plc in Lagos, the Motor flex is a specially designed Third-Party Motor Insurance policy with extended cover.
The Managing Director/CEO, Mrs. Cecilia Osipitan mentioned that the organization in its efforts to deepen insurance penetration developed unique insurance products at competitive rates aimed at assisting policy holders in risk mitigation.
The products are GNI Motor Flex, Great Savers Delight (GSD), GNI Fire Proof and Personal Accident Insurance (PAI) which are duly approved and certified by the industry principal regulator, the National Insurance Commission (NAICOM).
Osipitan said that the GNI MotorFlex offers a wide scope of protection cover in addition to all the benefits of Third-Party Motor Insurance. She further explained that the scope of cover of GNI MotorFlex Insurance includes:
Third-Party Limit up to N1,000,000 which takes care of legal liabilities for third party bodily injuries, death or property damage while the vehicle is on the road; these third parties include pedestrians, other vehicles, occupiers of these vehicles and properties owned by third parties. Own damages of N100,000 with Driver’s medical expenses of N10,000 at an affordable premium of N7,500.
GNI scribe stated that the need to bridge the gap between the compulsory Third-Party Motor Insurance and Comprehensive Motor insurance owing to the fact that the Comprehensive Motor Insurance is perceived as “insurance for the Elites due to cost” and Third-Party Motor Insurance as “Let my people go policy without claims benefit” became pertinent in order to reduce premium loss due to the failure by some vehicle owners to purchase motor insurance which according to some Analysts totals about N530 billion yearly as reported in TechEconomy Publication.Conclusively, she mentioned Great Nigeria Insurance Plc has put in place a-stress-free underwriting documentation process in all its branch offices nationwide.
Also lending her voice, the company’s spokesperson, Ms. Oyinkansola Sobande stated that every vehicle owner is mandated by law to have the Third-Party Motor Insurance cover; although many members of the insuring public and third party road users have not fully realized the importance of Motor (Third Party) Insurance in Nigeria.
Motor (third party) Insurance covers the insured’s (policy holder) legal liabilities for death and bodily injuries to third parties and third party property damage.
While remedies for bodily injuries and death are unlimited since we cannot put value on life, the limit for third party property damage is N1million. Third Party Motor Insurance is very important as far as third party road users are concerned.
However, many vehicle owners desire to have a cover that provides more benefits than the regular Third-Party Motor Insurance but at an affordable premium not as high as the Comprehensive Insurance.
This discovery intimated the organization to develop a customized policy that will meet the specific needs of the target public. GNI MotorFlex insurance is an insurance package that takes care or the insured’s car as well as the third party.
Naicom releases web aggregator guidelines

By admin

National Insurance Commission (“NAICOM”) issued the Insurance Web Aggregators Operational Guidelines (the “Guidelines”) which set out the regulatory framework for the deployment and operation of web aggregator platforms within the Nigerian insurance secto

A web aggregator is a company registered under the Companies and Allied Matters Act (CAMA) and licensed under the Guidelines, to act as an intermediary between insurance companies and the public.

The functions of a web aggregator include:

Maintaining a website for providing information on products of different insurance companies.
Providing comparisons on prices and features of products offered by different insurance companies; and
Offering leads to an insurance company.

Essentially, the Guidelines provide a framework for the licensing, registration and regulation of web aggregators and regulate their business relations with insurance companies. While web aggregators are required to obtain operating license from NAICOM, insurance companies are required to obtain “No Objection” from NAICOM to be allowed to carry on a web-based insurance business. The Guidelines took effect from the 1st of February 2022 but creates a 60-day window for full compliance with its provisions by existing web aggregators and insurance companies.

This article highlights key provisions of the Guidelines and the likely impact on the Nigerian insurance industry.

Licensing, Registration and Renewal

An entity that intends to obtain a web aggregation license from NAICOM is required to comply with the following:

Be incorporated as a company with the Corporate Affairs Commission (CAC), with a minimum share capital of five million naira (N5m).
State in its Memorandum of Association that its main objective shall be the business of web aggregation.
Have qualified personnel, not below the level of an Assistant General Manager, to be designated as Principal Officer, who shall be responsible for managing the company on full time, and who must possess the prescribed minimum academic and Information Technology (“IT”)-related professional qualifications, and at the same time meet the criteria set by NAICOM for “Fit and
Have all its key employees possess relevant certification in Insurance and IT.
Obtain approval from the Nigerian Communications Commission (NCC).
Pay a non-refundable application fee of five hundred thousand naira (N500,000) and a licensing fee of two million five hundred thousand naira (N2,500,000), and also take a professional indemnity insurance cover of not less than twenty million naira (N20 million); in addition to meeting the prescribed documentary requirements. • Provide details of its technology infrastructures (including Information Technology), proof of domain name registration, a 5-year business plan including financial projections, and risk management framework. There will be a physical verification of the entity’s head office address and technology infrastructures, before the licence is granted.
Execute Service Level Agreements (SLAs) with named insurance companies/brokers.

A license granted to a web aggregator shall only be valid for two (2) years, subject to suspension or cancellation by NAICOM. A web aggregation licence shall be renewable each year, subject to NAICOM’s prerogative and upon payment of an annual renewal fee of one million naira (N1m). However, application for renewal is required to be submitted at least 45 days before expiration of the license.

Likewise, an insurance company interested in offering its products on a web aggregator’s platform and thereby seeking to obtain “No Objection” from NAICOM, is required to apply to NAICOM in the prescribed manner, with the following documents attached:

SLA signed with the Web Aggregator it intends to partner with.
A copy of the appointment letter it issued to the partnering Web Aggregator.
Board approvals or resolutions in support of the partnership; and
A copy of its risk management framework on web aggregator operations.

Operational Standards and Business Obligations

The Guidelines prescribe the mode of operations of web aggregators and insurance companies and establish code of conduct for them in relation to their respective web aggregator platforms. By the same token, business obligations of web aggregators and insurance companies, as well as restrictions applicable to operations of insurance companies in relation to their respective web aggregator platforms, are explicitly stated in the Guidelines which include the following:

A web aggregator is required to enter an SLA with an insurer, or a broker intended to partner with, prior to the provision of web aggregation services. The Guidelines prescribe the standard clauses that must be included in an SLA
To prevent web aggregators from engaging in anticompetitive practices, the Guidelines prescribe transparency in the transmission of leads to an insurer. Thus, a web aggregator is required to use Lead Management System (“LMS2) in transmitting the data of a customer to insurers. LMS is defined in the Guidelines as the software deployed by a web aggregator for recording, filtering, validating, grading, distribution, follow-up, and closure of leads from the enquiries received on its website with an intention to buy insurance products.
To ensure data security and protection, a web aggregator must comply with IT security procedures and prevent unauthorised access and misuse of customer data, in the transmission of leads to an insurer.
A web aggregator is required to act in good faith and ensure adequate due diligence, as well as disclose the relationship between the client, web aggregator and insurer always.
A web aggregator is required to develop website portal or search utility to enable a client to gain several quotes via an electronic e-quote form. It shall also enter into agreements with several insurance companies to provide a comparative quote to potential clients, based on pre-determined list of specified needs as disclosed by the potential clients.
A web aggregator is prohibited from advertising on its website. It is also not allowed to display information on products and services of other financial institutions or fast-moving consumer goods (FMCGs) companies. In like manner, it is disallowed from operating multiple websites for lead generation or operating other websites belonging to other entities for the purpose of insurance product comparison.
A web aggregator is required to ensure adequate back up of data as may be required by its operation, as well as have well documented and tested business continuity plans.
A web aggregator is under obligation to put in place IT security and data privacy policy, duly approved by its board and, in compliance with all relevant laws and regulations.
A web aggregator shall, along with all its employees, comply with the provisions of the Insurance Act 2003 and all regulations made under/pursuant to the Act. By the same token, they shall comply with all other regulations issued by NAICOM from time to time.
An insurance company shall not engage any person or entity who owns or maintains a website not licensed by the NAICOM under the Guidelines.
An insurance company shall neither make any form of advance payment to a web aggregator nor pay any remuneration after termination of agreement with a web aggregator.
An insurance company is required to obtain and maintain records of leads or data obtained through the LMS from each web aggregator, as well as details of the policies sold out of the leads or data obtained including information on premium payments.

Financial Reporting & Disclosure Obligations and Prudential Records

The Guidelines prescribe certain reporting and disclosure obligations on web aggregators. In particular, a web aggregator is required to:

prepare, and submit to NAICOM, annual reports including:
(i) Balance Sheet or Statement of Affairs at the end of each accounting year;

(ii) Profit and Loss Account;

(iii) Statement of Cash/ Fund Flow; and (iv) any additional statements on web aggregator’s business which NAICOM may require. Accounting year, for the purpose of the Guidelines, shall be a period of 12 months beginning from January 1st and ending on December 31st. All accounts to be prepared shall be in compliance with the International Financial Reporting Standards (IFRS).disclose to NAICOM any material changes in its composition within thirty (30) days of such change. It shall also seek NAICOM’s prior approval to effect any change affecting its Principal Officer, Directors, Registered Name, etc. In like manner, it shall also submit to NAICOM information regarding list of qualified persons, outstanding claims arising from Professional Indemnity Policy, and acquisition of properties. Also, from time to time, a web aggregator shall disclose to NAICOM any information that may be required in line with the provisions of relevant extant legislation.

maintain at its Head Office or any other designated branch office, records of its business operations. Also, a web aggregator is under obligation to keep and retain for a period of not less than ten (10) years, all electronic records, books and documents, statements, contracts notes and the likes, maintained by it under the Guidelines.

Sanctions & Remedies and Dispute Resolution

NAICOM has powers under the Guidelines to inspect the premises and operations of a web aggregator to determine compliance with the provisions of the Guidelines or any extant relevant laws and regulations. Where any act of non-compliance is determined, NAICOM is empowered to take any intervention measures or remedies, or steps prescribed in the Insurance Act1. The applicable penalties range from administrative sanctions to withdrawal/ cancellation of license and/or prosecution, depending on the nature or gravity of the infractions as well as the stipulations in the Insurance Act and the NAICOM Act2.
The Guidelines provide for an appropriate complaints redress mechanism, to be jointly put in place by a web aggregator and the partner insurance company. This is to ensure that complaints from clients/customers are promptly and appropriately addressed. For disputes arising between a web aggregator and the partner insurance company, the Guidelines state that the provisions of the SLA with respect to Arbitration Clause shall be exhausted, before such disputes are referred to NAICOM. A person who is affected in any dispute arising out of insurance transactions has the right to refer the matter to NAICOM.

Commentary

As the regulatory authority for the insurance industry, NAICOM is empowered pursuant to the Insurance Act and NAICOM Act, to issue regulations governing insurance business in Nigeria.

The Guidelines seem to have regard to current market trends and industry outlook for the insurance sector. According to analyses and projections by Augusto & Co. (a research, credit ratings and credit risk management agency) in its 2022 Insurance Industry Report3, insurance penetration rate stands at less than one percent (1%) in Nigeria. The industry’s gross premium income (GPI) has also continued to stagnate at ₦520.1 billion (US $1.4 billion) when compared to previous years. Figures released by the National Bureau of Statistics (NBS), showed that the financial sector (consisting of financial institutions subsector and insurance sub-sector) contributed 3.10% to the overall nominal gross domestic product (GDP) as at Q4 2021. Insurance sub-sector’s share of the contribution stood at 7.82% compared to financial institutions sub-sector’s share of 92.18%.

However, the industry is reported to have shown signs of resilience and potential for growth, following restrictions in product distribution encountered during the COVID-19 induced lockdowns of 2020 (and some part of 2021) and the huge claims it has had to pay following the destruction of properties that trailed the ENDSARS protests in 2020. One unique development during these crises was the increase in the use of online channels to market and sell insurance products resulting in an upscale in consumers’ and insurance companies’ online presence. Before now, the insurance industry has leveraged the more structured data in the banking industry (through the adoption of bancassurance) and the strategic alliance with Fintechs (through InsureTech) to improve sales and grow premium income. With web aggregation encouraging more people to search and stay online, insurance companies can easily adopt online target-marketing campaigns to re-orientate the insurable public about the need to embrace insurance products.

With the coming into operation of the Guidelines, online marketing and sale of insurance products, increased insurance awareness in the market, and a deeper insurance penetration among the public, are expected in the near future. Also, the regulatory framework within which web aggregators can operate in providing information to potential insurance consumers and giving leads to insurers, has now been made crystal clear. We note that among other issues, consumer protection and the prohibition of anticompetitive practices (two principal issues to be considered in the insurance industry) have also been clearly outlined in the Guidelines. It is also noteworthy that the Guidelines have broadened the compliance obligations of web aggregators and insurance companies due to certain returns now required to be made to NAICOM.

The Guidelines categorically state that, the duty to seek information on understanding and complying with its provisions, rests on the participating web aggregators and insurers. As the 60-day timeline for complying with the Guidelines expires in the first week of April, companies operating in the Nigerian insurance sector need to seek appropriate advice on confirming their additional obligations under the Guidelines.