The Committee recommends that the Australian Securities and Investments Commission amend Regulatory Guideline 165 to:
- require general insurers to provide clear and comprehensive information about both Internal Dispute Resolution and External Dispute Resolution to clients at time of claim lodgement;
- require general insurers to provide information to clients at the time of claim lodgement on the right to seek from Financial Ombudsman Service an independent external expert report (such as a hydrology report);
- prohibit general insurers from commenting to policyholders on the merits of a dispute;
- prescribe an Internal Dispute Resolution model which avoids multi-tiered components; and
- automatically escalate a claim that has not been settled within four months to an internal dispute should the General Insurance Code of Practice amendment to this end not be implemented.

Recommendation 9