Introduction 簡介
Part II explains practices commonly found in Hong Kong’s travel insurance market. Travel insurance brings together different types of cover, whose terms and operation can vary considerably. Identify the relevant policy section before applying its terms, as a rule governing one section cannot simply be applied to another.
The actual claims cases in the notes help explain practice. Each outcome depends on the particular facts and the wording of the policy involved. An apparently similar incident therefore does not, by itself, establish that another claim must be paid.
The Insurance Complaints Bureau began on 16 January 2018, replacing the Insurance Claims Complaints Bureau. Some cases in the notes were determined by the Insurance Complaints Bureau; others were settled directly between claimants and insurers without adjudication by the former Insurance Claims Complaints Bureau. The examples are therefore not all decisions of a complaints body.
The notes also explain that the former Insurance Claims Complaints Bureau’s Complaints Panel had authority under its Articles of Association to take a wider view than a strict interpretation of policy terms. In assessing good insurance practice, it drew particularly on the expected standards in The Code of Conduct for Insurers, especially Part III: Claims. Both the wording and this decision-making context matter when studying a case. [IA 2021 Study Notes](https://www.ia.org.hk/en/supervision/reg_ins_intermediaries/files/P6_SN_Eng_2021_final.pdf)
Travel Insurance Agents 旅遊保險代理人
The travel insurance agent category was introduced into the Insurance Intermediaries Quality Assurance Scheme in 2006 so that travel agents and their staff could sell and actively promote travel insurance under regulation. Under the former registration arrangement described in the notes, only travel agents licensed under the Travel Agents Ordinance could register as travel insurance agents, with their staff registering as responsible officers or technical representatives. Employment by a travel agent did not itself amount to registration.
To identify Restricted Scope Travel Business, check the product, who arranged the travel services and whether the policy is annual. Under The Code of Practice for the Administration of Insurance Agents cited in the notes, agents could make and carry out contracts for their principals only where the insurance was travel insurance connected to a tour, travel package, trip or other travel service arranged for the customer by that same travel agent. Annual travel policies and travel policies for services the agent had not arranged were excluded.
For example, an agent arranging a travel package could handle related travel insurance within this scope, provided it was not an annual policy. An annual policy remained excluded even if the customer intended to travel only once. A separate property all risks policy for a camera did not become travel insurance within this scope merely because the camera would be taken on the trip. [IA 2021 Study Notes](https://www.ia.org.hk/en/supervision/reg_ins_intermediaries/files/P6_SN_Eng_2021_final.pdf)
The references here to registration, the former code and the Travel Agents Ordinance belong to the historical framework retained in the notes. Insurance intermediaries are now licensed directly by the Insurance Authority, while travel agents are licensed and regulated under the Travel Industry Ordinance. The questions on this page use the study-note framework described above. [IA direct regulation](https://www.ia.org.hk/en/infocenter/press_releases/20190923.html), [travel industry regulatory framework](https://www.cstb.gov.hk/en/policies/tourism.html)
Practice
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