The advantages of simplicity in the approval process have been articulated in our previous submissions. Incremental progress has been made however we continue to seek real enhancement in the form of a file and use system. Not only does it enhance efficiency, but it also enables the FSA to allocate resources to complex products that require more attention. Moreover, real product innovation requires insurers to offer truly new proposition to customers. At this dynamic era where our customers' needs are constantly changing due to lifestyles, ageing and technology, the insurance industry needs to catch up in offering better coverage in new diseases/illnesses as well as play a more active role in improving our customers' health. These initiatives often require global insights without necessarily locally proven experience. The current FSA product approval philosophy is to focus on proven local data and experience, this significantly hampers product innovation progress, and not in line with practices by overseas regulators, ultimately disadvantaging Japanese consumers. The EBC believes this recommendation to broaden the philosophy will also benefit also Japanese insurers. Covid-19 has led to various changes in the society including work from home and digitalisation. Simplification of the approval process is worthwhile considering to accelerate to bring new values of insurance product and services into the market. Concerning the change in the license led by FSA (Ex. The revision of MVA (Market Value Adjustment) time lag margin etc.), the FSA should give insurers enough time in view of IT development schedule in insurers etc. Furthermore, some product approvals have taken longer which in turn has had a negative effect on the process to introduce new products responding to customers’ needs on the market. Especially under these circumstances, a smoother transition is needed when the FSA personnel is rotating, as this would lessen the burden of “having to start all over.” Emphasising that tax-saving is not core values of insurance, the FSA is further promoting customer-oriented business operations and collaboration with the National Tax Authority.
- The FSA should introduce a system allowing insurers to register products, instead of having to obtain pre-approval. The FSA could retain the authority to conduct post-checks and issue withdrawal orders.
- The FSA should relax the requirement for new innovation to include global expertise and experience.
- The FSA should make certain that personnel rotation affects the product approval as little as possible.