Regulatory Sandbox in the insurance market: SUSEP Publishes Circular and Public Notice starting on April 1, 2020

In addition to CNSP Resolution No. 381, of March 4, 2020 (access our newsletter here), SUSEP Circular No. 598 was published on March 20, 2020, providing for the rules and criteria, for a determined period, for product operation, portfolio transfer and provision of information regarding the innovation project of Insurance Companies participating in the Regulatory Sandbox, upon compliance with previously established criteria and limits.

The criteria and limits were detailed in the Public Notice, which defines that the first 10 (ten) projects that reach the minimum score of 70 (seventy) points in a list of criteria set by SUSEP will be considered eligible for implementation, with the possibility of an additional 10 (ten) innovation projects.

In addition to the documentation provided in CNSP Resolution No. 381, it is necessary to present a detailed business plan, containing clarifications on the scope of the product and impacts on the consumer, among them, an exposition of the problem to be solved by the product/service offered, including a description of consumer gains and benefits and the projection of penetration in the market.

After approval of the project, the participating Insurance Company will receive a concession to commence the commercialization of its product, which will have a predetermined term of 36 (thirty-six) months, with automatic renewal of the ‘insurance ticket’ or commercialized policy expressly forbidden.

Interested Insurers may submit their projects to SUSEP from April 1, 2020, with a maximum deadline of April 30, 2020. The full text of the Announcement can be found at this link.

Demarest’s Insurance and Reinsurance team is available to provide any additional clarifications on this matter.