On behalf of the Canadian Association of Mutual Insurance Companies, I would like to thank this committee for allowing us to present our pre-budget submission.
The main purpose of CAMIC's submission is to talk about demutualization. For the first time in recent history, a property and casualty mutual insurance company has announced its intention to demutualize. This could have a significant impact on the whole mutual insurance industry, which CAMIC doesn't want to see happen.
CAMIC represents 91 Canadian-owned property and casualty mutual insurers, a sizable portion of the 106 mutual insurers operating in Canada. In turn, these 106 mutual insurers represent a third of the 316 property and casualty insurers competing in the Canadian market. In 2010 CAMIC members served 5.1 million policyholders, employed directly and indirectly in excess of 15,000 people, and underwrote $4.9 billion in premiums or 12% of the non-government Canadian market.
Consistent with their democratic values, mutual insurers provide their members with a right to vote at the annual and special meetings of members.
Policy holders elect the board of directors of their company, approve its by-laws and its financial statement, and determine the company's orientation.
Most mutual insurers were formed by farmers between 100 and 170 years ago. At that time, it was difficult for them to find insurance or to find insurance at a reasonable cost. To obtain the insurance they needed, farmers formed mutual insurance companies that were based on a commitment by each participant, called a member, to insure each other against named perils. The objective of the mutual insurer was then, and still is, to provide tailored insurance products needed by the members at the best cost possible.
Each year, as the case may be, the board of directors decides to allocate the profits generated in that year by the insurer to the surplus of the company, or to provide policy rebates to policy holders, or to use the money for social goals. The surplus of mutual insurers is the annual accumulation of the allocations of profits to the surplus fund of the company. That was done over four to six generations.
As may be expected, those companies that successfully built large surpluses over the last four to six generations become vulnerable to demutualization attempts for the purpose of generating personal windfall revenues.
You may recall that, some 11 to 12 years ago, a number of life insurance companies indicated their intention to demutualize to become stock companies traded on the stock market. In response, the government of the day amended the Insurance Companies Act to allow the demutualization of mutual insurance companies, and the Minister of Finance implemented regulations on the details of how the demutualization of an insurance company could occur.
Shortly thereafter, the market share held by mutual insurance companies went from 50% to less than 5%.
In December 2010, the Economical Mutual Insurance Company, a federally supervised mutual insurer, announced its intention to demutualize and transform into a stock company. However, while the company has over a million global insurance policy holders, it allowed fewer than a thousand of them to vote.
In response to Economical Mutual's request, the Minister of Finance announced in the June 2011 budget his intention to develop regulations for the demutualization of property and casualty insurance companies. In July 2011, the Department of Finance held consultations on the issue of demutualization. CAMIC participated in those consultations. However, we would like the finance committee of the House to express its support for the position adopted by CAMIC on this issue.
CAMIC is strongly opposed to creating an environment where advisers, boards of directors, management, and policyholders could withdraw substantial personal financial benefits from the demutualization of P and C insurance companies. CAMIC believes that if the surplus accumulated over many generations by mutual insurers is given to current policyholders or, especially, to a small minority of current policyholders, as could be the case with Economical Mutual, this will create a circle of self-interest amongst stakeholders that will become one of the most significant drivers of the process. CAMIC is of the view that the surplus fund of a mutual insurer is permanent and non-divisible; it is owned by the mutual insurance company, not the members, and it is not destined to be owned by the members. The surplus fund's purpose is to ensure the solvency of the insurer, to provide a high quality of service, and to assure the sustainability of the mutual insurer over future generations.
Recognizing that the Economical Mutual Insurance Company has a surplus of $1.2 billion and about one million policyholders and less than 1,000 voting or mutual policyholders, each mutual policyholder could in theory receive in excess of $1 million upon the demutualization of the company.