397

We would like to confirm the approach to contract boundaries for automatically renewable rider contracts classified as Health SLT (biometric risks), having the following features: - formal duration of the contract = 1 year;- it is guaranteed that at each anniversary (up to a pre-defined maximum age of an insured) the insurer will submit a proposal of renewal to the policyholder based on the premium tariffs effective at the anniversary date (portfolio tariffs taking into account individual features of the insured, e.g. age);- the insurer may change the portfolio tariffs over time without formal maximum limits;- the insurer cannot change the individual loadings to tariff as initial risk acceptance procedures include individual underwriting (incl. questionnaire and medical assessment where applicable) but the insurer has no right to re-perform underwriting at the contract renewal which eliminates the possibility of individual re-pricing at renewal (only the information from initial underwriting may impact individual's premium tariff; in particular claim history is not taken into account);- the insurer does not have: a unilateral right to terminate the contract (also renewals because renewals are obligatory for the insurer), a unilateral right to reject premiums payable under the contract (also under renewals), a unilateral right to amend the premiums or the benefits payable under the contract at individual policyholder level. Based on above features and looking at the examples on interpratation of "Policy renewals" and "Interpretation of 'unilateral right'" in Final Report on Public Consultation No. 14/036 on Guidelines on contract boundaries, we conclude that premiums from renewals are within contract boundary of existing contracts.