New ULIP norms: A whole new ball game for insurance players  

June 29, 2010

 Insurers are gearing up for a number of changes in the way they sell ULIPs after the new norms passed by the insurance regulator

While the Insurance Regulatory and Development Authority’s (IRDA) new norms for Unit-linked Insurance Plans (ULIPs) are good for consumers, private insurers are protesting that they could see the end of the product and they will sink into the red again or remain loss-making.

They fear that agents would prefer to sell traditional plans since ULIPs would turn less attractive. Interestingly, some even fear that stricter rules may spell the death of ULIPs, which have been their biggest product in the past five years. Were this to happen, it would spell another important turning point in the insurance industry.

While most insurers contacted by Moneylife were guarded or positive in their public response to IRDA’s new rules, some have refused to respond and claim they are still studying the implications. “On the face of it, the impact of these guidelines on customers is favourable, with lower charges, guaranteed returns, etc. In the medium to long run, these changes could seriously impact choice of investment options to customers, restrict  product design & innovation, increase new business strain and call for increased capital requirements for insurers—thus impacting the profitability of insurers,” said Deepak Sood, managing director and chief executive officer, Future Generali India Life Insurance Co Ltd.Insurers believe that IRDA’s new guidelines will affect their bottom lines. The say that capping of the charge structure will restrict the product portfolio and its flexibility. “Our bottom lines will be affected negatively and gradually even our top lines. With such norms, how does IRDA expect us to protect the policyholder’s money?” asked an official from Bajaj Allianz Life Insurance.

“These changes are likely to have significant impact on product mix, distribution mix and cost structures of the industry. The timeline for implementation of these changes is very aggressive," said Rajesh Sud, chief executive officer and managing director, Max New York Life Insurance.

“In line with expectations, capping of charges will impact margins adversely. With limited product differentiation, having a low and variable cost business model will be critical. This, in turn, will lead to cost-cutting across the sector, impacting distributor commissions adversely,” said an analyst from Edelweiss Securities Limited. According to Edelweiss, the capping of surrender charges is being considered a bigger blow than the cap imposed on the difference between gross and net yields, as it would not only restrict the ability to generate revenue, but also raise the persistency risk borne by the insurers. 

“Secondly, the commission structure can’t sustain an agent’s income; (the) agency channel will suffer badly. I hope we don’t land up in a situation where the product is very good but no one is willing to sell it,” said Kamesh Goyal, Bajaj Allianz Life Insurance country manager and chief executive officer.

A Reliance Life Insurance official, who spoke to Moneylife on the condition of anonymity, said that the insurance companies would also now shift their focus to selling more traditional plans. In fact, during the turf war between SEBI and IRDA, where insurance companies were banned from coming up with new ULIP products, insurers started coming out with more traditional plans. He says that the plans would now look more traditional then ULIPs.

“We understand that IRDA is simultaneously coming out with treatment of discontinuance-linked insurance policies. Under these regulations, the insurer will not be able to recover the incurred expenses (particularly under large value policies) fully as the regulator has prescribed the limits of discontinuance charges not only by percentage of annualised premium, but also in absolute value,” Mr Sood added.

Probably the thorniest issue for insurers is the stipulation that all pension products should guarantee a return of 4.5% to protect the lifetime savings from adverse fluctuation at the time of maturity. Insurers believe that this would not be possible for a long-term product and investments in ULIPs will now go to safer outlets like debt and securities where the yields are low.

“Because of the guarantee structure being introduced in pension plans, insurers will now play safe, as they can’t invest in equities, which means the upside is lost as everything is invested in securities and debts,” the official from Reliance said, adding that ULIPs will now become more of an endowment plan.

GN Agarwal, Future Generali’s chief actuary feels that there will be a drastic impact on the industry. According to him, more than 50% of ULIPs will be withdrawn from insurance companies and nearly all pension plans linked with ULIPs will be withdrawn. He went on to add that insurance companies whose revenues were solely based on ULIPs would be severely affected. He added, “They (the new norms) are too restrictive and pension products will be hit a lot, it would almost be impossible for life insurers to guarantee 4.5% on a long-term insurance product.”

Insurers in the past have maintained that insurance must be sold on a commission-based model and are marketed on mutual relations. Nearly 80% of ULIPs are sold in rural and semi-urban parts of India. Life India Council’s secretary general SB Mathur has said in the past, “Most of these sales are relationship-based, where it is very awkward for an agent to charge his client for doing his work.”

The new framework reduces agent commissions considerably as insurers would now have to ensure that they can charge their customers 4% of the annual premium paid. Agents selling ULIPs will be less motivated and they may shift to selling traditional plans like endowment plans, as commissions are higher. The commissions for selling traditional plans are still 30% to 35% in the first year; in the second and third years the commissions is 7.5%; from the fourth year onwards, the commission is 5% for a 15-year policy.

However, one must note that the move of capping charges by IRDA does comes as a surprise, especially when its chairman, J Hari Narayan, in the early weeks of June, came out in support of insurance agents and the commission given to them as he felt that it would bring about smooth functioning for the distribution of insurance, at an event in Mumbai. He had said, "With the kind of sustained activity, which an insurance agent has to undertake, the number of times he has to meet a prospect before a sale can be concluded and the kind of post-sales service that he has to provide for the insurance holder, a commission-based model is necessary. The remuneration (to agents) is not excessive; there cannot be a lower-cost method for distribution."

ULIPs are hybrid products that combine elements of investment and insurance, and have been a big investment magnet for insurance companies. According to the Life Insurance Council of India, an industry body representing 23 life insurers, of the Rs2,00,000 crore-plus life insurance premium collected in the first 11 months of 2009-10, more than Rs91,000 crore came from ULIPs.

The new guidelines have increased the lock-in period for ULIPs from three to five years mainly to ensure that they become a long-term insurance product rather than a short-term investment option. During this period, no residuary payments on lapsed, surrendered or discontinued policies will be made. Top-up on insurance premiums will now be treated as a single premium, meaning that every top-up that one makes will have to have an additional insurance cover backing it as well.

 — Aaron Rodrigues