I am taking a brief break from my read through the bill - pen in hand because nothing beats manual note taking for etching important stuff into memory. Just reflecting on silly things already - in an effort to be very up to date and right-on advertising new licenses is specified as taking place on the "Internet Site" of the Reserve Bank.
It occurs to me that the bank might be trusted with a little more flexibility. I mean, we're still getting over a bunch of legislation that specifies written signatures, and while the Internet has been wildly successful, we may well have a new format in less than a twenty years, and in New Zealand we make a point of revising insurance law only once or twice in a century... still, this is only a draft, and if this is as bad as it gets we'll have precious little to submit on.
Speaking of matters to do with time, it's a reminder of how much current legislation owes to historical legislation when you come across the entry defining Lloyds as "...the society of that name incorporated by the Imperial Act known as the Lloyd’s Act 1871." You know, the Lloyds option looks interesting too.
Matters of definition appear to be a great relief to read - although I am taking more input on this as the week rolls on - as the definition of continuous disability insurance appears to be a deft piece of work to permit the continuation of the status quo - after all, this Bill is about supervising what we've got, not wrecking accepted market definitions of products.
Section 22, the notice period looks a bit light, given the requirement to be reasonable and the complexity of life operations, and the difficulty in making large changes to such businesses very quickly. I suspect that this is there because the nature of changes are expected to be either (a) minor or (b) apply to conditional licences for operations not yet commenced, but they can apply to existing, and the requested conditions are not limited in any way other than 'reasonableness'.
Section 26 looks a little confused, a quick reading left me feeling public notification occurs before the insurer has had a chance to respond, but I may be wrong.
Wide powers of search will capture IT managers and staff as well as the specified officers of an insurer - which all makes sense, but will mean better explanation of their role.
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