The FSC should include persons with disabilities in the planning of insurance policies and programs to strengthen its understanding of persons with disabilities and help it formulate underwriting assessment procedures that better meet their needs and serve as a reference for insurance companies when they perform underwriting reviews. (5) Since 2018, the FSC has included the insurance industry’s compliance with the laws and regulations governing the acceptance of disabled persons’ insurance applications. The FSC also included the Insurance Industry Guidelines for Insuring Persons with Disabilities as items to be inspected during on-site inspections. 106 Nonetheless, between 2016 and 2019, the commission was only able to identify two cases in which the rights and interest of persons with disabilities were violated and penalties imposed. 107 The results of this supervision differed significantly from the actual experiences of persons with disabilities. 108 According to data from the Financial Ombudsman Institution (hereinafter referred to as the FOI), 109 insurance disputes accounted for a large proportion of the complaints and disputes that it has received. Underwriting disputes related to rejected insurance applications or added premiums accounted for 5% of all life insurance industry disputes (non-claim-related disputes). No statistical data were available for insurance disputes involving persons with disabilities. On January 8, 2020, the FSC issued a letter to the NLIA and LIAROC requesting that they perform statistical analyses on the handling of complaints filed by 106 107 108 109 The FSC explained that when conducting onsite inspections of insurance companies, it offers its opinions, urges the insurance companies to make improvements, and follows up on the improvements made if it is found that the internal regulations of an insurance company has violated laws and regulations governing the applications of persons with disabilities, or if a company has engaged in discriminatory acts against persons with disabilities during the insurance solicitation, underwriting, and claim settlement process. According to FSC data, the violations were the following: “Insurance companies rejecting insurance applications because the insurers were persons with disabilities, or setting a maximum amount of insurance that discouraged persons with disabilities from applying for insurance,” and “not following the company’s internal regulations and verbally rejecting insurance applications (because the insurance salespeople assumed that the proposers would not be able to provide sufficient assessment data) during the solicitation stage.” According to the Control Yuan investigation report approved on October 20, 2020, persons with disabilities testified that (a) they were treated unfairly; (b) their insurance applications were denied; or (c) their insurance premiums were increased when they submitted their insurance application. If the reasons for the above were merely because they had disabilities, it constitutes discrimination. “Explanations of complaint and dispute cases received by the FOI” (Q1, 2021). 83

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