What I examine before an insurance advertisement runs

I write and approve insurance advertising on the assumption that the claim is the real test of what we said. Our legal and compliance team reviews every piece against Japan's rules on misleading representations and the industry association's display guidelines, and I rely on that review. My part is earlier and different: deciding which conditions are said aloud, which appear at the same size as the premium and which examples a viewer needs to understand what a policy will pay. For medical cover that means distinguishing hospital stays from outpatient treatment; for cancer cover it means the interval before a second diagnosis payment; for relaxed-underwriting plans it means the first-year reduction and the price difference from standard cover. Since 2024 we have tested these choices against a follow-up question to claimants and an explain-back sample at application. When the two measures disagree with response data, I report all three to the board rather than choose the one that suits the budget.

I have worked on both sides of insurance comparison. At Hakari Navi I ran the insurance business of a comparison site for four years and built a paid ranking whose disclosure was accurate and largely unread. At Tomoshibi Life I decide which comparison partners we use and on what terms. I distinguish between comparison tables, which help customers weigh premiums and benefits, and rankings or selections, which invite readers to treat an order as a judgement. Since October 2023, when Japan began treating advertising that hides the advertiser as a misleading representation, sites have labelled paid content more clearly, but labelling varies widely. We buy only positions marked as paid at the point of reading, we pay part of each fee when a policy reaches its fourth monthly premium, and we compare partners on thirteen-month persistency. I also review every public claim of ranking or satisfaction to check whose opinion the underlying survey actually measured.

A direct insurer lives or dies by acquisition cost, and most direct insurers measure it at the wrong moment. I measure cost per policy still in force at thirteen months, by channel and by creative, and I review it with our appointed actuary's team against the value of new business by product. That measure changes decisions. It showed that point sites, which paid users points for applying, produced cheap applications and expensive policies, because 41% of those policies lapsed within four months. It showed that some late-night television slots with poor response produced customers who stayed for years. It also exposed our own sales measures, which counted applications for two quarters after marketing had stopped. I build television response models by region and time slot, run search and social campaigns with in-house analysts and three retained agencies, and keep a single view of cost from the first contact to the thirteenth premium.

About a third of our enquiries come from people aged 65 and over, and selling to them at a distance requires different safeguards from a face-to-face sale. Since 2016 the law has required insurers to understand what a customer wants and give them what they need to decide before a contract is made, and the industry's guidance on older customers sets out several measures from which insurers choose. At Tomoshibi Life I designed, with our contact-centre and compliance leaders, a two-call process for applicants aged 75 and over: an explanation first, heard alone unless the applicant asks otherwise, then a second call on a different day in which the applicant explains back what the policy pays. Advisers on the second call are not paid on completion. I also check every advertisement aimed at older viewers against the plan a healthy applicant could buy more cheaply, and I route applicants to that plan first.

Japanese life insurance has spent much of the past decade explaining sales misconduct, much of it involving older customers, and public trust has fallen across the category rather than at one company. A direct insurer is tempted to present itself as the exception. I think that is usually a mistake: contrast advertising invites viewers to distrust insurance in general, and it promises a cleanliness no insurer can vouch for in advance. My approach is to make specific commitments that customers and the press can check, such as never asking anyone aged 75 or over to replace an existing policy in a single call, and to publish the results. Tomoshibi Life has adopted the Financial Services Agency's principles for customer-oriented business conduct and reports measures against them each year. I chose which measures we publish with our compliance team, deliberately including some that make us look worse, such as complaints from older customers' families.