Industry Questions/Comments
[Section 268(2) of the Insurance Act 2018]
For group policies the risk is accepted before the policy contract is issued to the group policyholder.
Plan members are issued certificates on enrolment which occurs at various times throughout the life of the policy contract. However, it is not that separate underwriting is done for each member and the risk associated with that member accepted before the certificate is issued. The risk is accepted for the group as a whole before the policy is issued. There is no correlation in this scenario between the acceptance of risk and issuance of the certificate since plan members are not denied entry to the plan based on risk or underwriting criteria.
Therefore, it is unclear how the 20 business day turnaround time is to be calculated if it is tied to acceptance of the risk, unless the interpretation is 20 business days after the request for enrolment is received by the insurer.
Central Bank of Trinidad and Tobago
Certificates issued to member of a group policy pursuant to section 268 (2):
- Upon acceptance of the risk to provide group life insurance, the insurer must issue the requisite policy contract to the policyholder as well as issue the certificates to the members of the group plan that were in existence at the time of acceptance of the risk. The policy contracts and the certificates shall be issued not later than 20 business days after the acceptance of the risk.
- Note that when members of the plan are added subsequently, the requisite certificates shall be issued no later than 20 business days after the notification to the insurer of the addition of the new member.
