Joint submission: Reforming flood insurance – clearing the waters discussion paper

The following is a joint consumer submission in response to the Clearing the Waters discussion paper released by the Australian Government on 5 April 2011. The Brotherhood of St Laurence, Choice, Consumer Action Law Centre, Financial Counselling Australia, Footscray Community Legal Centre, Insurance Law Service at Consumer Credit Legal Centre NSW and National Legal Aid have all contributed to this submission. We welcome the opportunity to comment on the discussion paper. Background on each of the contributors can be found in the Appendix.

We generally welcome the reforms proposed by the discussion paper, subject to the remarks made on each proposal below. In addition, we have suggested further reforms which were not canvassed by the discussion paper but which we think are nonetheless required to achieve a comprehensive response to issues around flood insurance. We expect that such reforms will also be considered through the Government’s Natural Disaster Insurance Review.

In brief, this submission addresses:

  • The proposed standard definition of flood
  • the proposed key facts statement
  • time limits for claims handling
  • Centrepay processing for premium payments
  • Further reforms

To read our submission, click here: Reforming flood insurance – clearing the waters discussion paper.

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