Talk to 10Life on WeChat
Premium financing open enquiry: replies from the IA and the HKMA
On 23 July 2026 10Life wrote an open letter to each of the Insurance Authority and the Hong Kong Monetary Authority, raising questions on suitability assessment, affordability verification and risk disclosure in the sale of premium-financed long-term insurance. Both regulators replied in writing on 21 August 2026. This page records the exchange and reproduces both replies in full and without alteration.
What is premium financing?
Rather than paying the full premium, the customer borrows most of it from a bank and pays interest each month. The loan generally carries a floating rate, so the interest bill rises with market rates. The policy is assigned to the bank as security. If the customer surrenders the policy, its cash value must first repay the outstanding loan and interest, and only the balance is returned to the customer.
With thanks
We are grateful to the Insurance Authority and the Hong Kong Monetary Authority for replying in writing within 30 days of our open letters.
Both replies set out, under the current regulatory framework, the requirements that insurers, insurance intermediaries and banks must meet in premium financing business, including suitability assessment, affordability assessment, disclosure of information, and the duty to ensure customers make an informed decision. Both also describe the relevant supervisory and surveillance work, including onsite inspections, offsite reviews and the joint inspection between the two authorities.
These are clear and specific statements of what the framework requires, and they reflect the work both authorities do to protect policyholders.
Timeline
10Life issues two open letters
10Life wrote to the Insurance Authority and the Hong Kong Monetary Authority, raising questions on suitability assessment, affordability verification and risk disclosure in premium financing, and asking each to reply publicly within 30 days. The open letters were published on our platform the same day.
The Insurance Authority replies
The IA replied in a six-page letter, responding to each of the three areas raised and setting out the three requirements under the “Treating Customers Fairly” principle: suitability assessment, disclosure of information, and informed decision.
The Hong Kong Monetary Authority replies
The HKMA replied in a two-page letter, explaining the bank’s dual role in premium financing as both a licensed insurance intermediary and the provider of the financing facility, the supervisory requirements applying to each, and the HKMA’s supervisory approach.
The full replies
Both replies are written in English. The complete text of each is provided below.
The IA’s reply is a six-page letter in English. The link below provides the complete, unaltered text.
Read the original (English)The HKMA’s reply is a two-page letter in English. The link below provides the complete, unaltered text.
Read the original (English)10Life's Open Letter to Regulatory Authorities
On July 23, 2026, 10Life issued an open letter to the Insurance Authority and the Hong Kong Monetary Authority regarding issues surrounding suitability assessment, affordability verification, and risk disclosure. 〈For details, please visit〉
