Replacement business: what PPR rule 19 asks of your brokerage
Rule 19 puts a 14-day paper loop between two insurers whenever a risk policy is replaced. What counts as a replacement, and what the record has to show.
A client asks you to cancel everything because they have lost their job. Before you do, check what the credit life policy owes them and what a lapse costs.
The message arrives on a Monday morning and it is always short. Please cancel all my policies, I have been retrenched. The reflex answer — “no problem, I will action it today” — is fast, feels helpful, and is usually the worst outcome available for both the client and the book.
Retrenchment is one of the few life events where a brokerage can do something immediately useful that the client did not ask for and does not know about. It is also the event that quietly drives a large share of lapses in personal lines and funeral business, months after the conversation you did not have.
Most South African clients with a vehicle finance agreement, a personal loan, a store account or a home loan are paying for credit life cover, usually sold by the credit provider rather than by you. Since the credit life insurance regulations under the National Credit Act took effect on 10 August 2017, those policies have had to provide prescribed minimum benefits: death, permanent disability, temporary disability, and — in defined circumstances — unemployment or the inability to earn an income for reasons other than disability.
The unemployment benefit is the one that matters on a Monday morning. Where it applies, the policy pays the instalments due under the credit agreement for up to twelve months, or for the remaining repayment period if that is shorter. The same regulations capped what may be charged: a maximum of R4.50 per R1 000 of the deferred amount on credit facilities, unsecured loans and most other agreements, and R2 per R1 000 on mortgages.
Two qualifications matter before you tell a client they are covered. Retrenchment cover cannot be sold to someone who was not employed when the agreement was taken out, so a self-employed client or a pensioner may hold credit life without the unemployment benefit. And agreements concluded before the regulations came into force are not automatically on the new terms. So the answer is never “you are covered” — it is “bring me the credit agreement and the policy schedule and I will tell you what you have.”
What the client needs to gather, in practice: the credit agreement number, the retrenchment or termination letter from the employer, proof of UIF registration or application, an identity document, and bank statements showing the instalments. Claim notification windows are set in the policy wording and they are short. A client who takes six weeks to find the paperwork can lose a benefit that was worth twelve instalments.
Once income has stopped, something has to give. Your job is to decide with the client what gives, rather than letting a bounced debit order decide it for them. The general rule: cover with waiting periods or age-rated premiums is expensive to rebuild, so it is the last thing to cancel.
| Cover | What happens if the premium stops | The move to suggest instead |
|---|---|---|
| Funeral cover | Lapses after the grace period; a new policy later restarts waiting periods and reprices on current age | Reduce the sum assured or remove extended family members and keep the policy alive |
| Credit life | The debt is left unprotected precisely when the client is least able to service it | Claim on it. Cancelling it is the opposite of what the situation calls for |
| Motor — financed vehicle | The credit agreement usually requires comprehensive cover; lapsing it is a breach | Raise the excess, review the insured value, reconsider optional extras |
| Motor — unfinanced vehicle | Total loss becomes the client’s problem | Third-party, fire and theft as a deliberate downgrade, discussed and recorded |
| Household contents | Loss of everything after a break-in or fire | Reduce the sum insured with a clear warning about average and underinsurance |
| Risk life and disability | Re-underwriting later on current age and health, if the client is still insurable | Ask the insurer about a premium holiday or a paid-up option before cancelling |
The waiting-period argument is the strongest retention tool you have, and it is not a sales line. A client who cancels a funeral policy held for six years and buys a new one in eighteen months is a client who has thrown away six years of waiting periods and will pay more for less. Saying so plainly is better advice than any discount.
A missed instalment is not only a cash problem. A failed collection triggers a bank fee, then a second attempt, then a lapse that nobody at the brokerage sees until the client tries to claim. If the client’s new income arrives on a different date — a severance payment, a UIF benefit, the first pay run of a new job — change the collection date with the insurer rather than hoping the account holds. Our failed debit order use case sets out the recovery sequence, and the broader lapse dynamics are in our lapse risk playbook for South African brokerages.
Reducing a sum insured, moving from comprehensive to third-party, or cancelling a risk policy are all advice under FAIS. The file needs to show what the client’s circumstances were, what you recommended, what the client chose, and what you warned them about — particularly where the client insisted on something you advised against. Two lines in a WhatsApp thread that say “as discussed, dropping to third-party means the insurer will not pay for damage to your own vehicle; confirm you would like to proceed” are worth more at an ombud than a perfect file note written afterwards.
Note also that this is a service conversation, not marketing. It concerns policies the client already holds, so it does not depend on marketing consent — but a client who has just told you they cannot afford their cover is not a client to add to the next promotional campaign.
In ORIS, this is the kind of situation the Opportunities & Risks view exists for: the client shows up as an attrition risk rather than a routine service query, the conversation stays in the shared inbox where a colleague can pick it up, the AI drafts a reply for the adviser to check rather than sending anything on its own, and a lifecycle trigger can put the three, six and twelve month check-ins in the diary while the conversation is still open. Nothing here needs automation. It needs the conversation not to be lost.
Retrenchment is temporary far more often than it is permanent, and the brokerage that checks in at month three is the one still holding the business at month eighteen. Set three reminders when you close the conversation: a short check at three months, a cover review at six, and a full review at twelve when the credit life unemployment benefit — if one was payable — is running out. The month-twelve conversation is the important one, because that is the cliff edge the client will not have diarised. More on holding onto clients through hard periods in our writing on client retention.
No. The prescribed minimum benefits apply to credit life policies within the scope of the regulations, and unemployment cover applies in defined circumstances — notably, it cannot be sold to someone who was not employed when the agreement was concluded. Older agreements may sit outside the current terms. Always read the actual policy schedule before telling a client what they hold.
You are not the intermediary on it and you should not pretend to be, but telling a client that a benefit may exist and helping them find the paperwork costs you nothing and is exactly what a client remembers. Point them to the credit provider or the insurer named on the schedule, and record that you did.
Usually, where the insurer offers one. It keeps waiting periods and underwriting terms intact, which is the expensive part to rebuild. Terms vary widely by product and insurer, so ask before promising anything — and make sure the client understands what happens at the end of the holiday.
Flag the client, change the debit order date rather than letting collections fail, and diarise the follow-ups at the moment of the first conversation. Most retrenchment lapses are not decisions; they are unattended debit orders.
The retention logic travels; the legal detail does not. The prescribed minimum benefits and premium caps described here come from regulations made under the South African National Credit Act. Credit life exists across the region under different rules, so check what your own regulator and the policy wording actually require before advising a client.
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Rule 19 puts a 14-day paper loop between two insurers whenever a risk policy is replaced. What counts as a replacement, and what the record has to show.
What the 15-day grace period in the Policyholder Protection Rules really covers, when it does not apply, and how a broker handles a reinstatement request.
Average cuts a claim in proportion to the shortfall. How Southern African brokers run a yearly sum-insured check on WhatsApp and record what the client answers.