The FSA issues paper makes proposals for a the introduction of a framework to make the process more transparent without undermining legitimate commercial confidentiality. The paper also discusses options, within this framework, for the formal introduction into the negotiations of a policyholders representative.
The options include:
- Modified status quo, which takes the present approach, together with reports by the Appointed Actuary, an independent actuary and/or an Independent Expert, and the ultimate no objection scrutiny by the FSA, but with the greater disclosure referred to above.
- The FSA acts as a negotiator, taking on an explicit role to negotiate on behalf of policyholders, in addition to its role as regulatory scrutineer.
- Actuary or independent expert as negotiator, whereby an independent actuary and/or independent expert would be appointed to make sure that the best possible deal in terms of policyholder benefits has been obtained in the attribution process.
- Proxy negotiator. In this variation a qualified third party (whether individual, group or organisation) would act as policyholder negotiator by proxy.
- Policyholder consultation between the company and the policyholders in an open and public manner.
