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    <description>An insurer was held responsible for ensuring informed consent and full disclosure when advance renewal premium for a three-year policy was collected through a corporate agent. Because the application material did not disclose the arrangement and did not show clear consent from the prospect, the policyholder-protection regulations were breached; the insurer could not rely on the absence of complaints. The refund direction was upheld only to the extent of interest on the advance premium actually received by the insurer, together with penal interest of 2%, while interest attributable solely to the agent was excluded. The monetary penalty was also sustained as the continuing breach and statutory cap supported the quantum.</description>
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      <description>An insurer was held responsible for ensuring informed consent and full disclosure when advance renewal premium for a three-year policy was collected through a corporate agent. Because the application material did not disclose the arrangement and did not show clear consent from the prospect, the policyholder-protection regulations were breached; the insurer could not rely on the absence of complaints. The refund direction was upheld only to the extent of interest on the advance premium actually received by the insurer, together with penal interest of 2%, while interest attributable solely to the agent was excluded. The monetary penalty was also sustained as the continuing breach and statutory cap supported the quantum.</description>
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