Fiona Murphy feels there is something rather significant missing from the Financial Conduct Authority (FCA's) first steps into a consultation on the ageing population and financial services.
The FCA's new consultation into how older people engage with financial services is welcome but in my opinion, protection is conspicious by its absence in the Discussion Paper which kicks off the review.
This is something we've all come to expect - with the Financial Advice Market Review as the latest example of protection being off the regulator's radar.
Despite this I remained hopeful. When I opened the Discussion Paper, I was looking for a chapter, or at least, mentions of life insurance, the over-50s market, IHT planning using whole of life and how insurers will have to overhaul their policies as people live longer.
Many long-term products such as term assurance are becoming increasingly unfit for purpose given massive demographic shifts.
In the next five years, the number of consumers aged over 65 in the UK is expected to increase by 1.1 million, and the proportion of people aged over 100 will rise by 40%.
Those aged 85 and over represent the fastest growing segment of the UK population.
There is a sense of urgency to address the financial needs and access to advice for this rapidly growing cohort.
Mortgages, pensions and banking are all directly discussed in the Discussion Paper. Certainly, they are areas ripe for reform.
The pension chapters discuss how to stop people from running out of money as they live longer.
Meanwhile, the banking experts in the paper discuss encouraging long-term savings habits, debt, how to communicate with this cohort and the risk of exclusion as banking services digitalise.
And the mortgage articles highlight how many older people are trapped in poor deals and are unable to pay off their mortgages as their retirement incomes and savings barely cover outgoings.
There were also a number of mentions of long-term care, which highlight that it is a huge issue, but there no real answers as to what to do from a financial services perspective.
All in all, I found a document neatly skimming around the edges of protection.
The paper ought to have approached financial products that complement these areas such as the importance of life or critical illness cover so spouses/partners could pay that mortgage or have a slightly more comfortable life after the illness or death of a loved one.
Or how there are products in the market now that enable greater flexibility for later life care.
Yvonne Braun, director of long term savings policy at the FCA talks about insurance policies but it was quite sparse and I believe more focussed at general insurance.
I came away thinking, "these bits could fit into the protection discussion". But no-one explicitly drew the dots together within the paper.
FCA acting chief executive Tracey McDermott's forward said: "Our aim is to ensure that consumers have access to products and services that are well-governed and deliver value."
On this basis, one area I would have thought definitely needed some inclusion is the guaranteed acceptance over 50s market: its historic poor value for money and the fact that some policies do not pay out if you no longer pay your premiums.
Some policyholders may benefit from, going down the medically underwritten whole of life route instead of taking out such policies.
We have seen some insurers make strides and try to adapt the model - such as introducing premium guarantees or limited underwriting. Self-policing is all well and good, but I think the regulator really ought to mention the divided whole of life market in the forthcoming consultation.
The other issue, that I alluded to earlier, is that life insurance and terminal illness cover will eventually need to cover much longer terms and underwrite risks differently as medical developments lengthen lives.
Take developments in cancer care: that is certain to change the playing field.
Insurers will need to adapt to the changing need of the customer here and do so soon. What impact will greater numbers of longer and sicker lives have on insurer capacity? That is the other side of the coin.
Finally, I was also interested in definitions of ageing and the discussions of vulnerability and financial capability which dominated the paper.
Many older customers become vulnerable and therefore having a solid approach to identifying mental capacity and understanding Powers of Attorney should be at the top of the industry's radar.
Braun did reference the code for vulnerable customers developed with BIBA that will ensure staff can recognise vulnerable customers at renewal and the need to continually review legacy policies.
But the paper does rightly point out at various points that older doesn't necessarily mean ‘vulnerable.'
Here, I think the paper missed a trick in discussing healthy, active older people who may want something more from their policies.
Hopefully, these will all be addressed in the actual consultation when it is delivered.
Those are just some of my points I feel the FCA should explore further. What are yours? Please let me know in the comments box below.
The deadline for responses to the Discussion Paper is 16th April 2016.
If you want protection to be part of the FCA's investigation into older customers, visit HERE and tell the regulator.
