FSCO.UBI

This online reading, Usage-Based Automobile Insurance Pricing in Ontario provides updated considerations and filing requirements which reflect FSCO’s experience with UBIP programs since October 2013.

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Study Tips

The most important piece of information regarding this FSCO bulletin is that it was updated in 2016. The old version on the syllabus was the 2013 and there are several differences. The most crucial different that you have to know relates to prohibited & permitted uses of UBI data. In the 2013 version, the only permitted use was discounting of rates (unless the customer signed an 'opt-in' clause permitting non-UBI uses like marketing.) The 2013 version specifically prohibited verifying other rating variables and fraud prevention. The 2016 version reversed this rule and now specifically permits verification and fraud prevention.

Although the other differences between 2013 & 2016 don't seem as important, it might be an idea to quickly scan them using this external link to the source article: (The updates are listed near the top and the 4th bullet point refers to the change in prohibited/permitted uses.)

• Usage-Based Automobile Insurance Pricing in Ontario

Other than that, this article is just a lot of memorization. It's only a middle-ranked article but it was asked in both Spring & Fall of 2018. Does that mean its rank is rising, or that it won't be asked again until 2020? Hard to say. If you're pressed for time, at least drill yourself on the old exam problems and read the article over a few times. You'll probably absorb to then be able to make good educated guesses if they throw in something different on the exam.

Estimated study time: 1 day (not including subsequent review)

Pop Quiz!    :-o

Which of the following are prohibited risk classification elements in Ontario Auto:

• claims where fault < 50%
• credit history/score
• territory

Click for answer.

BattleTable

Based on past exams, the main things you need to know (in rough order of importance) are:

• facts about UBIP the insurer must communicate to the insured
• valid uses and other issues regarding UBIP data
• goals & concerns of UBIP programs

Top Questions ← Questions you absolutely need to know!

reference	part (a)	part (b)	part (c)	part (d)
E (2018.Fall #6)	FSCO.PPA	UBI valid uses: - non-renew?	UBI valid uses: - investigate claim?	FSCO.PPA
E (2018.Spring #4)	reasons for UBIP: - versus credit-scoring	UBIP concerns: - from FSCO	transparency: - insurer communication
E (2016.Fall #2)	see FSCO.PPA	see FSCO.PPA	see FSCO.PPA	(d) see FSCO.PPA (e) UBIP data: valid uses
E (2016.Spring #3)	see AAA.CrdSc	see AAA.CrdSc	SCENARIO: - consent
E (2015.Fall #3)	transparency: - insurer communication	competition: - how to promote

In Plain English!

Intro

Let's begin our discussion of UBI (Usage-Based Insurance) by defining what it is. (Note that the acronyms UBI and UBIP are sometimes used interchangeably – UBIP is Usage-Based Insurance Program)

Question: define the term usage-based insurance (UBI)

• a type of auto insurance based on:

   - how far a vehicle is driven

   - where it’s driven

   - how it’s driven

This information is not self-reported, however. An insured participating in UBIP must have a device installed in their car that transmits this information automatically and in real-time to the insurer. This is called telematics. Telematics is a branch of information technology that deals with the long-distance transmission of computerized information.

This is already starting to get complicated. And Alice isn't so sure she wants an AI device in her Ferrari tracking her speed and recording where she goes. (Drag-racing on Lakeshore Boulevard and wild, late-night parties at Drake's mega-mansion probably won't be good for her auto insurance rates.) UBI raises the issue of data privacy, something that's very much at the forefront in our increasing digital world. So why bother with UBI at all?

Question: identify benefits of UBI

driver benefits:

• more control over rates (safe driving and low mileage can lower claim costs & rates charged)

society benefits:

• fewer accidents, less congested roads

But there are always pros & cons...

Question: identify concerns regarding UBI from FSCO's perspective

• privacy of data
• accuracy of data
• manipulation of data (by insured – this could mean hacking or otherwise altering the data)

And 1 final very basic question that probably wouldn't be asked on an exam but seems like background information:

Question: in broad terms what does a UBI contract cover

• an agreement between insurer & insured beyond a typical auto policy:

→ insured agrees to install & use device

→ insurer agrees to use data only for specific purposes

The source text has 15 sections that cover a variety of topics. I've organized them into 3 groups:

• Sections 1-6: Privacy, Transparency, and Consent
• Sections 7-8: Data Transferability, Collection, Use, and Disclosure
• Sections 9-15: Filing and Other Considerations

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Sections 1-6: Privacy, Transparency, and Consent

It's important to know that FSCO regards telematics data as personal, even though the device can't always identify the specific driver. (It's generally assumed that the driver is the named insured.) Insurers are then responsible for ensuring that privacy regulations are met. To meet this goal, they should use privacy by design principles, although this is not discussed any further within this reading.

Two crucial considerations regarding telematics data are transparency and consent.

Question: prior to UBI enrollment, what must insurers inform consumers about

what personal information is collected (speeding, rapid acceleration, hard-braking, swerving cell-phone use,...)

   who has access (insurer)

   how is it used (often only to give discounts, never to decline, cancel or non-renew)

   when is it disclosed to other parties (if customer consents or if required by law)

what are the consumer's rights regarding this information

(and customers must have the opportunity to give or withhold consent to collect this information)

Section 2 in the source reading is the most substantial of the first 6 sections and covers miscellaneous points related to consent and consumer rights.

Question: can the insurer use UBI data for non-UBI purposes (Ex: marketing)

• the insurer cannot require this as a condition for participation
• the consumer may opt-in to receiving marketing (or having their data used for other non-UBI purposes)

This is a very reasonable restriction on the insurer. We are all flooded with useless spam emails and the explicit opt-in condition helps reduce that.

The next point is very interesting. If you want to switch insurers, does your current insurer have to help you do that? The probably wouldn't want to, but with UBI they have to. Part of the reason is to lower barriers and allow the customer to seek the lowest rate.

Question: do insurers have to facilitate the transfer of UBI to another insurer

• yes! (insurer should provide customer with their UBI data and reports)

The remaining sections 3,4,5 cover some common sense considerations transparency:

• The insurer must provide customer support. Duh. The customer should be able to discuss, challenge, and if necessary correct their UBI data.
• The insurer must provide feedback on driving habits so the customer can improve. (Double-Duh)
• The insurer must keep the customer informed about how the UBI data impacts premium. (Triple-Duh)
• Mid-term rate changes in UBI discounts are permissible but the consumer must be know the maximum (undiscounted) rate. (Ok, that's enough Duhs!)

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Sections 7-8: Data Transferability, Collection, Use, and Disclosure

Section 7 provides a few more details on the transferability of UBI data from one insurer to another. We discussed above that although a customer's current insurer may not want to do this, they are required to do so when possible. This is to lower barriers and allow the customer to seek the lowest rate. But UBI is still fairly new and not everyone insurer collects data in the same way. If UBI data from the current insurer is not transferable (for whatever reason) the new insurer may still offer a UBI discount equal to what the customer is currently receiving. This is called a matching discount but is subject to certain conditions, including that the new insurer has its own UBI program and has proof of the customer's current UBI discount. The source text has a bullet point list for this, which is a favorite type of CAS exam question, but I really don't think that particular list is important.

But what follows in section 8 is very important for you to know:

Question: identify prohibited uses of UBI data

• decline, cancel, non-renew, surcharge

Question: identify permitted uses of UBI data

• discount rates
• verify other rating criteria (like garaging location or mileage)    ← this was previously prohibited by FSCO under the 2013 (oudated) version of the bulletin
• fraud prevention (like investigating suspicious claims)    ← this was previously prohibited by FSCO under the 2013 (oudated) version of the bulletin

And remember that even these permitted uses are permitted only after the customer has provided explicit consent.

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Sections 9-15: Filing and Other Considerations

Let's start this discussion by reviewing an old exam problem. I mentioned above that UBI is still fairly new and not all insurers even offer UBI. Even for insurers that do, their Ontario data may be thin and that presents filing issues. Their UBI data may simply not be credible enough to justify the desired classification system. But if they can't get a UBI filing approved, they will never get enough credible data. FSCO recognizes this catch-22 and is willing to accept a filing containing UBI data from other jurisdictions.

This leads into part (b) of this old exam question:

E (2015.Fall #3)

Question: how does FSCO promote a competitive UBI marketplace

• FSCO accepts UBI data from other jurisdictions
• FSCO requires insurers to facilitate transfer of UBI data to another insurer

Ok, so FSCO encourages a competitive marketplace in the way described above, and there are certainly benefits to the customer in terms of lower rates, but there are still barriers to customer adoption. In particular, the cost and operation of a telematics device installed in a customer's car. FSCO stipulates that this cost should be borne by the insurer. Furthermore, if UBI data collection involves a customer's smart phone, the insurer must advise the customer of any additional cellular network data requirements and offer a choice between WiFi and cellular data transmission. This is especially important as it relates to low-income customers who otherwise might not be able to bear the costs of participating in a UBI program.

As with all insurer expenses, any specifically UBI expenses must be disclosed in a filing.

Question: identify insurer costs associated with a UBI program

• device, DTA (Data Transfer & Analysis), marketing, 3^rd-party providers

Obviously these costs are expenses that must be included in any UBI filing. But there's more...

Question: identify non-expense items that must be included in a UBI filing

which variables are measured (speed, distance, acceleration, deceleration)

how variables are measured (frequency, occurrence, thresholds)

how the data is normalized (total occurrences, averages, minimums, maximums)

+ all other relevant UBI claims experience (severity, frequency, loss costs)

We're coming up to section 12 on something called UDAP (Unfair or Deceptive Acts or Practices). But before we go on, recall my comment in the Study Tips about there being a lot to memorize for only a middle-ranked reading. I wish the middle and low-ranked readings had less content but unfortunately that's not always the case. If you're running short on time, make sure to at least drill yourself on the old exam questions. If you then just read this wiki article a few times, you'll be able to take a good educated guess if something slightly different comes up on the exam.

But back to UDAP. (Click the link for a quick explanation.) Insurers must make sure they're in compliance with UDAP and for UBI this means they must comply with the affiliated insurer rule. In other words, if 1 affiliate in a group of companies offers UBI, then either all affiliates must offer it or the consumer must be informed that they can arrange coverage through an affiliate that does.

Now here's what Alice and I think is a high-probability question from section 13:

Question: identify 4 data considerations related to UBI [Hint: @TASS]

@Termination (at Termination)

• ensure: [ no further data is captured, transferred, analyzed ] after UBIP or policy termination

   Accuracy

• ensure: [ compliance with UBIP discount, data errors fixed, customer disputes resolved, customer hasn't tampered with data ]

   Security

• ensure: data [ capture, transfer, analysis ] is done in secure environment

   Storage

• ensure: data [ deleted, anonymized ] when there is no longer a clear business need

(Exs: customer opts-out, doesn't renew, or data is not relevant for discount)

The final noteworthy topic (section 14) relates to 3^rd party service providers. Basically this means the insurer must be sure that any 3^d party providers abide by the same privacy and consent standards as the insurer writing the business.

Question: identify the insurer's responsibilities regarding privacy & consent for 3rd party service providers

• insurer is responsible that 3rd parties meet the same standards as the insurer
• that 3^rd parties don't use the data except for UBIP purposes unless customer opts-in

Question: identify elements of an insurer's contract with 3rd party service providers

confirm that 3^rd party:

• offers same level of privacy protection as insurer
• has the required service standards
• considers succession issues when switching providers

The 2 questions and answers above say essentially the same thing – that if the insurer contracts work out to 3^rd party, they're responsible for ensuring that 3^rd behaves appropriately, and that these assurances are written explicitly into the contract.

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A Bloom's Question

Take a look at the following question that combined UBI and credit scoring. It's a long question but the idea is that an insurer wants to introduce a new rating variable: # of dental visits by insured:

E (2016.Spring #3)

parts (a) & (b):

• the question specifically directs you to consider the reading on credit scoring, AAA.CrdSc
• if you've studied that reading, you'll immediately see how it relates

part (c):

• the question doesn't tell you to relate your answer to UBI concepts, but that's the first thing that popped into my head

(UBI is very much concerned with consent and data issues)

• a good answer might list what an insurer must communicate to the customer to promote transparency (how the discounting works, who has access to the data,...)
• the examiner's report said that many answers were accepted

This leads me to the final UBI topic: similarities & differences to credit scoring.

similarities: both are relatively new, potentially controversial, require informed consent, and are generally used only for discounting

differences:

• data source: UBIP requires a device installed in the car, credit scoring uses a credit bureau
• data quality: UBIP data is thin, credit scoring data is highly credible
• usefulness: UBIP is too new to know, credit scoring data is useful (statistically significant)

Do you know anyone who actually has a telematics device in their car? (I don't!)

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