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Second provincial regulator approves electronic pink slips


July 30, 2019   by Jason Contant


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Newfoundland and Labrador has become the second jurisdiction in Canada to approve the use of electronic proof of auto insurance (EPAI) for drivers in the province.

The Superintendent of Insurance of Newfoundland and Labrador, Renee Dyer, announced the decision in a bulletin Monday. With this approval, drivers in the province can now present their EPAI to law enforcement officers during a traffic stop.

“Electronic documents may be delivered through smartphones, apps, email or tablets,” Dyer wrote in the bulletin. “The use of electronic information is not required but, if EPAI is offered by an insurance company, a person may consent to its use.”

Kelly Hickman, president of the Insurance Brokers Association of Newfoundland and Labrador (IBAN), told Canadian Underwriter Tuesday that a common call to brokers is clients looking for a copy of their pink card.

“So being able to offer them an electronic version will likely appeal to those clients comfortable with technology and using smartphone apps,” Hickman said. “Some brokers have already been offering access to electronic pink slips through their BMS apps or other providers, and it may be difficult getting consent from those clients after the fact. It will be important to obtain consent to ensure those clients acknowledge and understand the limitation of using their eSlips.”

The Centre for Study of Insurance Operations (CSIO), along with its members, developed and launched a customer solution in February 2018, soon after Nova Scotia’s insurance regulatory become the first in Canada to approve the use of EPAI. The My Proof of Insurance solution, available to CSIO members at no additional cost, was created in response to an evolving customer demand for a more seamless, digital experience with their insurance providers.

In January 2018, Nova Scotia’s insurance regulator become the first in Canada to approve the use of EPAI. Since then, industry scuttlebutt was that the new Financial Services Regulatory Authority of Ontario (FSRA) would allow the use of EPAI this summer. When contacted for comment in May, FSRA referred Canadian Underwriter to the Financial Services Commission of Ontario (FSCO), which said “the launch date has not yet been set for the approval of electronic proof of insurance in Ontario.”

FSRA told Canadian Underwriter Aug. 2 that the organization “continues to work with the government and stakeholders to enable the use of electronic pink cards for consumers. We have no further updates at this time.”

A January 2018 survey of more than 1,200 Ontarians by the Insurance Bureau of Canada found that 74% of those polled wanted the option of receiving their insurance documents (proof of insurance card, insurance renewals) electronically.

Catherine Smola, president and CEO of the Centre for Study of Insurance Operations (CSIO), said Monday in a press release that the standards body applauds the Newfoundland and Labrador government’s decision to approve the use of EPAI.

“Electronic proof of auto insurance is an example of the industry collaborating effectively to provide a solution for a consumer pain point,” Smola said. “We are continuing to work with stakeholders across Canada and expect regulatory approval in other provinces to follow.”

The bulletin from Newfoundland and Labrador’s insurance regulator also issued some required guidelines and principles for insurers and brokers to offer EPAI. Among them:

  • Advise your clients of the following risks and limitations of their use of EPAI:
    • the absence of Internet services may limit the availability and accessibility of EPAI on demand
    • Although EPAI is acceptable in Nova Scotia and Newfoundland and Labrador, clients travelling outside these provinces will be required to produce a paper-based insurance card that may require direct confirmation with their insurer or broker
    • customers are responsible for any loss or damage to their phones that may occur while their phones are in the care, custody or control of a third-party who has the authority to request access [a police officer, for example].
  • Provide detailed instructions to clients on how to produce the EPAI on their device to show law enforcement officers or others who have authority to request access
  • Create EPAI as a downloadable product with lock screen capability that can be stored in a secure manner on the device. The downloadable product should not be able to harvest any data or interact with other downloadable products on the device
  • If your client chooses to use EPAI, you must obtain a written consent from them wherein they state they acknowledge and understand the risks and limitations outlined above and they consent to use EPAI.

“Brokers will need to develop consent forms as well as detailed instructions on how to access eSlips on a variety of devices to provide to clients,” Hickman said. “For those brokers who have been offering access to eSlips through their online apps or other providers for a few years, it will now be necessary to obtain written consent from those clients in order for them to be able to use the EPAI.”


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