The "insurance" game - a monitored future

Discussion in 'Canada' started by GreatWhiteNorth, Nov 25, 2020.

  1. GreatWhiteNorth

    GreatWhiteNorth Long timer

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    A friend sent me this (I live in MB, not AB), but I feel this has ramifications for the vehicle insurance industry across Canada, including motorcycles. From the article:

    " the Alberta government introduced Bill 41 on Oct. 29 to modernize the Insurance Act."

    https://edmontonjournal.com/opinion...ce-reforms-could-cost-albertans-their-privacy

    Sounds innocuous, but when you read deeper into it, "the law is designed to make affordable insurance contingent on drivers relinquishing their privacy... expanding the use of usage based insurance (UBI) technology that tracks mileage, driving behaviors, and much more."

    To qualify for a discount, drivers will have to agree to download an always on tracking app to their smartphone. If this passes in Alberta, it will likely spread to other provinces.

    With all the integrated computerization and connectivity happening in new vehicles, how long before your car, motorcycle or phone rats you out to Big Brother for speeding, or going offroad backcountry, etc.? That appears to be where this is headed.
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  2. Candubrain

    Candubrain Been here awhile

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    Sadly you are correct. If any of us took the time to actually read and fully understand the lawyer talk that we click the accept box on we would most likely not agree.

    I was riding in Switzerland last year and had a speeding ticket come in the mail after I was home. I was doing 63 kph in a 60, fine was $45.00 US funds. Telling this story to someone from there, he enforced 60 is the limit, not 61. He went on to tell me that if I had been going 80kph, that after my overnight all inclusive stay I would have been subjected to a physiological interview to determine if I was trying to kill myself, was I trying to leave my children without a father, etc....he wasn't joking, it's the norm in Switzerland.

    Guess its just a matter of time before it becomes the norm here too.
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  3. GreatWhiteNorth

    GreatWhiteNorth Long timer

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    Somehow, that Rush "Red Barchetta" future doesn't seem that far off. This was released in '81:

    <iframe width="545" height="409" src="" frameborder="0" allow="accelerometer; autoplay; clipboard-write; encrypted-media; gyroscope; picture-in-picture" allowfullscreen></iframe>
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  4. Lycan1

    Lycan1 Grizzly herder

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    One of my favorite song and Albums. Listen to Witch Hunt as well. Very apt in today's world.



    Resist as long as possible with that monitoring crap.
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  5. ommoran

    ommoran Experienced Newbie

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    So, I have some experience here.

    Usage based insurance has been fairly broadly available in many (forward thinking) provinces. Remember, it wasn't all that long ago that you could start paying your insurance premiums on a monthly basis. This is an extension of that policy.

    UBI is already available in many, if not most, US states. It bills based on a mixture of mileage and, as you point out, "safe driving" habits. The same goes here - although in Ontario, for example, I think right now it is only based on mileage.

    Insurers are always trying to find ways to review, and reduce, risk. They are ultimately risk-averse, after all. That's why they employ so many actuaries - the nerds of accounting school. Until recent breakthroughs in technology, they have had to look at historical data, and that's why young men paid so much more for insurance than equivalently young women, for example. Or why you pay more in BC for motorcycles over 750cc than for smaller bikes. The statistics say that more powerful bikes are more often in single vehicle accidents, perhaps, or more prone to speed. The stats say that young men showboat more often, or take more risks, or are simply less cautious and inexperienced.

    Those are blanket applications, and they aren't necessarily fair. UBI provides near real-time data, to allow near real-time adjustment to a policy. UBI would have been great during the pandemic when no one went further than the grocery store, because it's also based on MILEAGE. Yup, they will look to catch the folks that rate their vehicles for pleasure, but commute from Oakville to Bay Street every day, or commute on the streets of Vancouver. But you may end up saving money.

    Two things to note, as well: motorcycles probably won't get this for a long time. ICBC here in BC doesn't have a difference for commuter or non-commuter motorcycles. They just have a motorcycle category. Some progressive companies that write bikes in private provinces like AB and ON might start to do it, but it's unlikely as bikes are usually secondary, or often tertiary vehicles that don't put on a lot of miles. The other thing to think about is that there will still be choice - for a long time, you'll be able to buy an annual policy. But you could possible reap some savings from a UBI policy.

    When UBI comes to BC.... I will absolutely continue to buy an annual policy, for all the privacy and big brother reasons you note. Slowly, they will disappear, but it will take time.

    Two other thoughts. UBI is a stop-gap anyway, with private insurance. Vehicle autonomy will drastically change - likely kill - automobile insurance in North America and Europe. You'll buy your insurance as a monthly cost added to your lease/purchase price from the auto dealers. If you want to know more about what I think will happen there, let me know.

    The other point is that this change in legislation is to keep up with technology. It's not saying they have to go to a UBI model, it's just allowing an insurer to. Similar to the change to break the taxi monopolies and allow Uber and Lift. Someone pointed it out - soon, there will be a universal widget in each CAR (not a phone that can be left at home!) that each insurer can tap into. That will need a standard, and companies in competition often hate standards. So, they're working against each other for a while, and while competition is a good thing, it can also slow overall adoption due to needless complexity.

    My $0.02.
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  6. Adanac rider

    Adanac rider O.S.T.R. 62 Supporter

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    Since moving from another province I find insurance very complex and expensive in B.C. , I blame it partly on being different and me being stuck in a my old ways . We use a bigger company so it's hit and miss on the expertise of insuring multiple bikes with 2 insurance policies each. I think it's time to be down to 2 bikes total for the wife and I. I recently got a T-7 and that might have to be our 2-up bike, Having less power and protection from the elements will help me in future big brother monitoring. But I'm gonna miss C.C. and E.S. and ...... :(
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  7. grashopper

    grashopper Adventurer

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    I do not understand the reasoning of this practice. Maybe 50 years ago it applied that more cc's equals more power, but not at all like that now. Please explain to me why these days we are gouged by ICBC based on engine capacity rather than engine power. These figures are readily available to everyone so why is engine capacity used to set our exorbitant rates??
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  8. Brenski

    Brenski Been here awhile

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    My $0.02.[/QUOTE]

    Thank you for providing some background and a broader perspective. Much appreciated!
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  9. BetterLateThanNever

    BetterLateThanNever Nice, until you're not.

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    I think this is all fine in principle, but there are two giant issues not adequately addressed from my perspective.

    One is how accurate the 'data' is. Some of this information (speed, say) comes from the ECU, but some of it is inferred by algorithms from accelerometers. My new truck came with a feature that 'scores' my driving, and I've left it on out of curiosity. To give you just one example of how subjective it can really be, it records roundabouts as 'aggressive turns'. As is often the case, we accept the technology at face value, when in fact a lot of the risk lies not in our own conduct but in the assumptions of some computer nerd talking to a policy wonk. It sounds logical on the face of it, but I don't accept the notion that if we don't do anything wrong, we have nothing to fear.

    The other is who has custody of the data, and how can they use it? With the event data recorders in cars, it took a court case to establish that using this information was an invasion of privacy or misuse of the 5th Amendment or some such (it was a US case). Many new bikes have EDRs as well, by the way... anyway, the point is, can this data be subpoenaed in a civil case? Can it be used to deny warranty coverage? Insurance legislation doesn't always look at this, and insurance companies have no incentive to do so. It all feels a bit hasty and lopsided to me.

    EDIT - On the question of whether motorcycles will have this soon, you'll find that there are some ride logging apps out there right now trying to sort out how to monetize the data they're collecting on your riding habits. So no, not now. But it's not necessarily that far away.
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  10. ommoran

    ommoran Experienced Newbie

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    Generally, engine capacity is a linear expression of a horsepower/torque curve. As technology advances, ALL bikes of xxxCC start to make more power over time. So, it's somewhat constant. As to why that is the number, and not say 1000cc, or 500cc? I think it's probably based on a) what the mean value is (think of all the scooters and dual-sports that are under this number), and b) the fact that most bikes over 750 are higher horsepower and torque than those below. Never mind that my 2012 V-Strom 650 can dust many many HD cruisers with larger engines. The other answer is simple: they have to do something. This was what they chose. I wouldn't be surprised if we soon see graduated motorcycle licencing like in the UK and Europe, by the way. That's when they will change the classification, but it will still be cc based, no other metric.


    I agree that data security, use and integrity is a big component. However, when you sign your insurance policy, you are signing for the ability for the insurer to investigate into accidents. I am in claims, and I know for a fact that forensic engineers are often employed to get data from the EDR (Event Data Recorder) that is included in most vehicles from about 2010 up. So, absolutely it can and will be used in a civil case - and often to defend the party being sued. It's very useful as a defence, say, in cases where it's alleged that someone "jammed on the brakes" (you do get these from time to time), but the EDR records show otherwise. The other party will demand the production of that data in serious cases. I don't know about warranty, as that's a contract between owner and manufacturer, so it will differ from make to make as to what their wordings say. EDR data definitely cuts both ways. The kicker? Say your car is totalled. The insurer settles with you. They now own the car, so they can access the EDR without having to ask consent. Most of those times, it's a VERY serious accident. However, not consenting to a request will in my opinion be considered non-co-operation with the insurer, and would potentially invalidate coverage.

    With UBI, you'll be signing an agreement for the use of the data collected, entrust the storage to the insurer, and allow them to use it however they feel they should. In the era when everyone has an invasive Facebook account and a phone that throws ads at you because it's eavesdropping on your real-world non-telephone conversations with your spouse (You to your wife: I need medicine for my goiter; your phone: "See how these folks in Ontario get half off their goiter medication!"), I think most consumers understand that the data will be collected, stored, and used by the insurer. They are using their privacy as currency for potentially reduced insurance premiums. For a commuter in Toronto or Montreal or Winnipeg - not worth it. Surge pricing would be in effect during the morning and evening rush. However, someone that gets groceries and stays in the speed limit? Huge savings. This isn't for me.

    No problem, happy to give you my opinion. :-)
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  11. BetterLateThanNever

    BetterLateThanNever Nice, until you're not.

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    I appreciate you disclosing your bias. Thank you.

    Without meaning to sound dismissive, most of your argument turns on the fact that this is already happening anyway, and that we give up our data freely elsewhere for less benefit. I'd say the latter is untrue on the face of it ... nothing I do on Facebook is likely to ruin me financially unless I really try. As for the former, we need to remember that the basis of this argument is not an agreed upon acceptable level of risk for insurers. Insurance companies are corporations who derive the bulk of their income from risk management, both on the policy side and on the investment side. The ideal level of risk for an insurer is zero, especially when markets are volatile. Zero is what they will pursue if unchecked by either competition or regulation. That's just how capitalism works (something I'm generally a fan of, by the way, lest you wonder if I have an agenda). But insurance is something I have to have by law, and my provider wants to shift as much risk back on me as they possibly can... it's an inherently adversarial relationship in which the corporation is uniquely advantaged. So there has to be resistance when they - you - come up with a new way to reduce their exposure at our risk or expense.

    With motorcycles, I think the situation is even more egregious. Lacking a large enough pool to price risk in Canada, insurers in many provinces charge extortional rates... in my case, nearly the equivalent of what I pay for my car per bike, despite my bikes being capable of far less liability damage and being in use only half the year.

    So, I think it's important for people to hold insurers and regulators to account when this kind of thing comes up. UBI seems reasonable, but it's not necessarily, and the necessary checks and balances have to come from us.
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  12. ommoran

    ommoran Experienced Newbie

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    A fair argument, but again, my perspective is different. First, my points are simply that the legislation in AB that just went in is permitting insurers to do that. They are, per the capitalist model, giving insurers the ability to offer their customers choice. Choice and competition is good, on this we both agree.

    I disagree that insurer's ideal level of risk is zero. The higher the risk, the higher the premium, and the higher the premium, the more potential profit there will be, but the bigger the gamble they take when they accept underwriting that risk. Insurers are risk averse, yes, but are in the business of assessing and underwriting risk. Statistically, mile per mile, motorcycles are riskier for a host of reason - other drivers are inattentive boobs, some riders get on their bikes 3 times a year and are rusty - whatever. Yes, you need insurance by law. Your insurer is not shifting any risk back on you, at all. First, bear in mind that your Provincial Government both writes the Automobile Insurance Policy in your province (OAP-1), and also that they control the rates that insurers can charge by limiting the rate increases they can charge for automobile insurance. If your issue is mandatory insurance, then I refuse to agree with you. The government mandates liability to $200,000 in each province, for the greater good and the protection of the populace. If your argument is that they are trying to shift risk back on you when you're paying money to shift risk to them... you're incorrect. They charge what they are allowed, and the wordings are proscribed to them by the government.

    And as to your comment about your bikes being capable of far less liability damage, you live in Ontario. Ontario is a "no fault" province, where the terms of the insurance legislation has changed many times, but at the basic core of the changes (and the original ones were good, if unwieldy), the idea was to get rid of suing the negligent party. Change the system from one of retribution to one of rehabilitation. I was working in Ontario through most of those various legislation - Bill 68, Bill 164, Bill 59, etc. Many people in the industry were saying "they're trying to make it like WCB (now WSIB)!". I look at that now as a good thing. The idea of suing an employer because you were injured on a job-site is now anathema to most Canadians. That's what happening with the changes now to ICBC's no-fault system coming in in May, and the system currently in Ontario. Stop making it about getting someone back and getting to shake your fist at them, and start making it about getting someone back to the condition they were in immediately prior to the accident. The intent is good, and good for our society as a whole.

    Now to your extortionist rates. What do the insurers do with the money they save by not having all the lawsuits and paying all the lawyers (where most of the money goes - 30% at least to your injury lawyer)? They have to pour that back into first party benefits, called Accident Benefits. They go back to you. The chances that you will be catastrophically injured on a motorcycle are an order of magnitude higher than if you are injured while in a car. Your extortionist insurance policy pays for several hundred thousand dollars of therapy, home modification, and other necessary and expensive items when you are flung from your bike. There, when you need it. I've been to hospital to visit people whose son was in a coma as a result of an accident, and was going to have to go to a specialized rehab centre to learn to walk again. The insurer paid the entire cost of that - a private centre - and helped to retrain him to another and more lucrative career that could accommodate him after the therapy. I've seen insurers pay for vans modified with hand controls for people that have been paralyzed. I've seen people with "normal" neck and back injuries get fitter than prior to the accident, and keep it up. I've seen a lot of good done. The various systems are imperfect, but most people are glad to have them when they need them.

    I don't like that my motorbike's insurance, spread between two companies because ICBC, is about the same as the insurance for my car. That's the cost of riding a bike in our society. To give you perspective, I'd encourage you to take a look at the insurer's balance sheet. You mention investments, which ultimately insurance companies are - investment companies. They take your premium, they have to hold back an amount for reserves, and they can invest the rest in ways approved by the provincial government. Most insurers in Ontario run at a loss ratio of 105-110%. The magic number in Ontario to make money at automobile insurance was 108% - meaning that you're only paying out 108% of the premium you take in. If you actually pay out less than 100%, you make an underwriting profit - and raise eyebrows (like, telling your buddies that you saw a unicorn, or brought the hot stripper home from the strip club kind of raised eyebrows). Do you know why you get discounts if you bundle your home and auto insurance in Ontario? Residential policies - especially for detached private non-condo homes - make a profit. The bundling is to get your home business, not your auto. They use the home business to offset the losses in the automobile line. The draw isn't the vehicle insurance at all, in fact many insurers would get out of writing auto altogether if they could retain their licences and do so, but the government won't let them do that, either. These are all publically available stats, by the way.

    I know I won't convince you and that's ok. That's not my job. I'm just pointing out that the situation is probably a lot more nuanced than most would first believe. As to having a bias? Yeah, I sure do make my living in the insurance industry as do tens of thousands of other people. As did my father, and my brother. I suppose I have a bias in that I believe insurance is a good thing, the way a plumber believes indoor plumbing is a good thing. I think plumbing is a necessity - I bet if the plumber gets sued, he thinks insurance is a necessity too.
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  13. BetterLateThanNever

    BetterLateThanNever Nice, until you're not.

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    I understand that you do important work and that insurance is a valuable privilege. But I think this blinds you to the customer experience, some of which might be rooted in not understanding how insurance works... but some of which is surely rooted in the oligopolistic and regulatory protection insurance companies enjoy, and the fact that they don't actually make money on insurance at all, just as you say. They are primarily investment concerns, and as a serving director on a board that oversees an investment firm, I get what risk is and how it works. What I don't get is, for example, why my insurance company was so out of touch they refused to cover my CBR250R, but were fine with my Ducati Monster (the issue seemed to be fairings...). Or how you or they can claim that the risks alone justify the premiums... those of us in the risk business know that it isn't one thing, it's two: probability and impact. Yeah, maybe my bike is more likely to crash. But you could write it off for the cost of the bumper on my truck. Which, by the way, would do a hell of a lot more damage to your bottom line hitting a guard rail than my bike would, especially carrying a full compliment of passengers. Bikes may be more at risk of accidents, but the potential down side is far, far lower. It's simply not debatable, even in a no fault province. It's not "the cost of riding a bike in our society," it's the cost of being an unimportant line of business that insurance companies would love to shed, just as you say.

    But, fine, we've accepted that shitty deal as part of the bargain for riding motorcycles. My feeling is simply that given how little effort insurance companies have gone to, to serve the motorcycle market, they are not morally entitled to now put me under electronic surveillance and do with my data as they please. To bring this back on topic, you shouldn't get to do that until you've actually put the effort into quantifying your risk and pricing it fairly.

    Except that you do, because we have no real choice. And that, I'm afraid, will never get insurers much sympathy, even when it's warranted.
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  14. Dan Diego

    Dan Diego Long timer

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  15. ommoran

    ommoran Experienced Newbie

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    I have, throughout my career, had this argument. Motor vehicle insurance is a generally money-losing proposition. But I will be unable to convince you of that, as I have been unable to convince tens or hundreds of others before, and that's fine.

    I've made my point - I don't think that this is going to be the right choice for me. Neither do you think it will be the right choice for you. But it will be the right choice for many. My late 70s mother-in-law. My 17 year old daughter, who drives little, and cautiously. My ex-wife who is a speed-abider. Great for them, just not for me.

    As long as there are lots of people like me, you will get to buy annual policies. I get that insurance, on some level, rankles you - and therefore everything is nefarious, including both the way it is now and the way it might shift to. No matter the move made, you feel there is malintent behind it, and that is entirely on the insurer - not government, not the the legal bar, not the vehicle makers and their $5k bumpers, not the NHTSA and other organizations that make safety rules, not the public, just the insurer. Cool. I am sure I also have deeply held beliefs that I won't be swayed from - I hate Apple, Inc. in a seething fashion, for example. I gave you perspective from an experienced insider, so I've done my bit. I don't know if you wanted this to turn into a pile-on against vehicle insurance, and I'm sorry if I sort of spoiled that. You're entitled, and I will defend your right to, your opinion. Suffice to say - respecfully, I disagree.

    Good luck!
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  16. GreatWhiteNorth

    GreatWhiteNorth Long timer

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    I really like how this discussion is going. I'm surprised nobody discusses more the complete and total invasion of privacy aspect. There is no way, IMO, that insurance corporations should be able to demand that level of monitoring into your life, in exchange for obtaining a discount.

    Do insurers not already get a good picture of someone's driving habits from accident & speeding ticket data?
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  17. ommoran

    ommoran Experienced Newbie

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    Absolutely. And I agree on the issue of "invading" (really, it *is* trading) privacy for a discount.

    We are, as often, behind the times. Remember that our insurers are in fact a mix of Canadian and international insurance companies. Intact, Canada's largest, was a spin-off from ING, the dutch bankassurer. Intact has just expanded to purchase RSA (Royal Sun Alliance, a UK-based firm with many different brands in Canada) internationally. Intact also has sub-brands, such as Canadian Direct which they bought, and are folding into one of their other brands, Belair Direct. Aviva, likely number 2 or three on the list and swapping places with RSA, is based out of the UK. Lloyd's is still one of the largest insurers in Canada, but they do mostly commercial - in the vehicle insurance world, trucking, taxi fleets, etc. Then you have Canadian firms like Wawanesa or Optimum.

    My point with this is that many, MANY of these insurers have home offices outside Canada, or operations outside Canada. Even Wawanesa has a big operation in California. I was chatting with a co-worker who is 29, and came from Ireland about 3 years ago. They've had UBI there for going on 10 years, as they were an early adopter. Auto insurance rates there are what he calls "mental", even compared to here. Most of his friends chose UBI because, like a cell phone plan, it was pay-as-you-go. That's actually one of the attractive parts to most people, paying only for what you use. Tied into that has always been the issue of monitoring, something that definitely comes as part of the lower rate and pay-as-you-go scheme.

    @GreatWhiteNorth to answer your question about speeding ticket data and accident data - yes, sort of. I don't have first hand knowledge of how this works, so I'm using this as an example. You, with your clean record, are lumped into the same pool as someone who has had one accident (and the insurer has "forgiven that") and people with perhaps one speeding or other ticket that's only worth a few demerits. You are classed and rated as a pool. Your clean 5-year record has been lumped into the same pool as someone with an accident and one speeding ticket, and your rates are adjusted accordingly. So, your record is clean, but not everyone in your class is clean, which hurts you. Let's say you also commute - you're 16km from work, and the threshold to be charged as a commuter is 15km. So, you point out it's 16km, but you also are a shift worker. You go into work at 8pm and come home in the early morning. You're charged the same surcharge as someone who commutes 100km a day during the rush hour both ways. That's the commuter levy. The point is, they are blanket assessments. Plus most insurers don't care how many miles you drive a year. When I was an adjuster on the road, I would put 35,000 km on the car every year without blinking. That's an extraordinary amount for most people. I rated my car as business use, but have never had to give odometer readings during the year, or at renewal. What about those people who drive 60,000 km per year? They're in the same class as all the rest of us.

    If you have no accidents and follow the speed limits (a "safe" driver), you can with UBI get taken out of that pool. You can be rated based on your usage time (not during heavy rush hour), your actual mileage (16km for commuting), your average trip, your total (generally lower) miles per year - whatever. Under an annual policy, they have to ensure that they insure against people like me, when I was 35,000km per year. The commuter pool is a blanket pool, and you actually help to offset the costs for those folks that work 9-5 and commute way more than 25km. All of that adds up to exposure. With UBI, that gets rated by you, not by some class they have put you into. The charges are directly proportional to your use of the vehicle - just like gasoline.
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  18. BetterLateThanNever

    BetterLateThanNever Nice, until you're not.

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    Given that I've been reasonable and respectful of your job and your industry here, I'm not sure I deserve to be dismissed as a crank ("nefarious... malinent..." etc). So let's deal in some facts. Is it true that auto insurance is unprofitable? My Canada-only insurance company made more than a quarter billion dollars last year. They insure far more cars than they do homes (1.5 million vs 896,000), so even if car insurance isn't high margin in isolation, it obviously generates structural profits without undue risk. Their claims expense for that year was $2.15 billion on $4.3 billion of operating revenue - 50% - meaning their claims losses were covered by operations, not the sale of assets. Their balance sheet shows equity at $3.7 billion on total assets of $17 billion... risk priced in. So no, I don't think it's true that car insurance is a loser. I think it's spin that lobbyists promote to government in order to get concessions.

    You sell a product I'm required by law to buy. That means you're more privileged even than the phone company. And that means you shouldn't get to make all the rules or be allowed to substantially self-govern. Even telecoms and banks, two oligopolies that people can theoretically live without, are held to account to a special extent because of their privileged position. I'm just saying the insurance industry should be, too. And by saying you disagree, I assume you mean that you believe they should be allowed to collect and use the data they want without external governance. So yes, you're right. We do indeed disagree.

    And as I suggested earlier, I wonder if someone who spends his entire days managing the worst part of the insurance business is really in a position to consider the broader issue. I appreciate your 'insider's perspective', but nobody should assume that you can speak for the entirety of what makes an insurance company work.
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  19. BetterLateThanNever

    BetterLateThanNever Nice, until you're not.

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    Location:
    Somewhere in Canada
    I think we should be careful not to create a false binary, here, ie that the two alternatives are UBI and no controls at all. In fact, at least here in Ontario, there are a number of usage based pricing policies already in place... things like business use, drive-to-work use, the distance of your commute, your postal code, and even annual mileage. My car policy covers me for 20,000km a year, and the bikes for 10,000 each. Exceed these, and I get rerated or risk losing the coverage. So what's really happening here is that we're "trading" a ton of privacy for only a tiny bit of additional risk-pricing data. It's a bad deal.
    #19
    Night_Wolf and GreatWhiteNorth like this.
  20. GreatWhiteNorth

    GreatWhiteNorth Long timer

    Joined:
    Dec 2, 2009
    Oddometer:
    5,563
    Location:
    Winterpeg - site of flatness beyond belief
    Can't speak for ICBC, or SGI, but MPI here in MB has been profitable. They actually have lowered rates because less driving and less accidents with the pandemic.

    These provincial government insurance corporations must really piss off the big private sector insurance companies. It will be a sad day IMO if/when they get sold off.
    #20