NIBA / Professionalism
4.2 Recommendation 8: Enhanced Vulnerability Provisions THE RECOMMENDATION The Code’s vulnerability factors should be updated to include persons affected by catastrophic events and otherwise align with the General Insurance Code of Practice. There should be a stronger commitment to identifying and helping those experiencing vulnerability. NIBA’s Position: NIBA supports updating the Code’s vulnerability framework. Clients facing their most difficult moments — including those affected by catastrophic events — deserve appropriate support and guidance from their broker. Questions: 12. What additional support obligations should the revised Code include? 13. Beyond catastrophic events, what client circumstances should trigger enhanced vulnerability provisions? 14. How should brokers identify when a client may be experiencing vulnerability? 15. Should obligations around support persons be strengthened? If so, how? 4.3 Recommendation 12: Explicit Record-Keeping Obligations THE RECOMMENDATION NIBA should amend the Code to include a new obligation to keep complete and accurate client records. NIBA’s Position: NIBA supports elevating record-keeping from guidance to an explicit Code obligation. Accurate, complete records are essential to ensuring that clients receive consistent, high-quality advice over time and to protecting both clients and brokers. Questions:
16. What records should brokers be required to maintain under the Code? 17. Should the Code specify requirements about record format or storage? 18. How long should brokers be required to retain client records? 19. Under what circumstances should clients be able to access their records?
14 / INSURANCE ADVISER FEBRUARY/MARCH 2026
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