The Autorité des marchés financiers (AMF) launched a public consultation June 15, about supplemental health insurance offered to members of college and university student associations, after AMF suspended informed consent measures requested of insurers in time for the September 2022 school year.
Prior to the suspension, the AMF had required insurers to ensure that each student gives informed consent to the payment of premiums to be voluntarily enrolled in the group insurance typically offered by student associations. It also required that insurers allow sufficient time for students to make an enlightened decision about purchasing group insurance in educational settings.
“After these actions were taken, various stakeholders expressed concern about the continued accessibility of such insurance plans for students,” the AMF writes in its consultation document, Group insurance offered to members of a student association. “February 9, 2022, the AMF announced a full review of the matter.”
In their preamble, the AMF writes that the obligation to adhere to sound commercial practices means treating clients fairly. “The insurer must provide its clients with appropriate information allowing them to make informed decisions about the products offered,” they write.
In particular, in recent years the AMF has taken an interest in automatic enrollment insurance products, including the optional group insurance offered to members of student associations. It says between 2015 and 2019 it continued to work with identified insurers to find solutions. Recommendations were issued to improve the information provided to students, the contents of invoices issued to each individual student, and to improve the coordination of invoicing periods and opt-out processes. “The insurers concerned took certain remedial actions to give effect to those recommendations; however, they were not able to act on all of them.”
The AMF’s suspension of the remedial measures initially required in time for September 2022 is currently in effect while the consultation is underway. Fundamentally, the AMF says its objectives are to maintain access to insurance products for students, and also to ensure adequate protection of students as consumers of insurance products.
In addition to the consultation document, the AMF has also created an online questionnaire for stakeholders to provide their feedback. The consultation will run until October 17, 2022.
