Complaint to Federal Insurance Ombudsman

To, The Federal Insurance Ombudsman, Federal Insurance Ombudsman Secretariat, fio_office_address Reference: fio_complaint_reference

Date: complaint_date

Subject: Complaint under the Federal Ombudsman Institutional Reforms Act 2013 against insurance_company_name in respect of nature_of_insurance_grievance.

Respected Sir / Madam,

1. That the undersigned, complainant_name, son / daughter of complainant_father, holder of CNIC No. complainant_cnic, residing at complainant_address, is the holder / beneficiary of insurance policy No. policy_number, type policy_type (life / health / motor / property / fire / liability / marine), issued by insurance_company_name (the 'Insurer') on policy_issue_date, for a sum insured of Rs. sum_insured, with annual premium of Rs. annual_premium, valid till policy_expiry_date.

2. That the present complaint concerns nature_of_insurance_grievance, particulars of which are as follows: detailed_grievance_narrative. The grievance first arose on grievance_date and concerns the conduct of the Insurer in respect of insurance_event (the insured event / claim submission / claim repudiation / claim under-settlement / mis-selling / breach of policy terms / failure to issue policy documents).

3. That on loss_event_date, the insured event of insured_event_description occurred at loss_location. The undersigned intimated the loss to the Insurer on loss_intimation_date and submitted a formal claim of Rs. claim_amount on claim_submission_date, supported by the documentation prescribed under the policy.

4. That, by communication dated insurer_decision_date, the Insurer has insurer_action (repudiated the claim in full / settled the claim only partially in the sum of Rs. partial_settlement / failed to settle the claim altogether / delayed the claim beyond reasonable time), citing the following ground(s): insurer_ground, which the undersigned submits is factually incorrect and legally untenable.

5. That, prior to approaching the Federal Insurance Ombudsman, the undersigned has lodged a written complaint with the Insurer's Grievance Redressal Officer on insurer_complaint_date bearing reference No. insurer_complaint_reference. The Insurer has, despite the lapse of the prescribed period of thirty (30) days, insurer_grievance_response (failed to provide a final resolution / provided an unsatisfactory response).

6. That the conduct of the Insurer complained of constitutes 'maladministration' under the Federal Ombudsman Institutional Reforms Act 2013, falls within the jurisdiction of the Federal Insurance Ombudsman under the Insurance Ordinance 2000, and amounts to: (a) breach of the Insurer's obligations under the policy and the principles of insurance law; (b) breach of the duty of utmost good faith owed by the Insurer to the policyholder; and (c) breach of the SECP Code of Corporate Governance for Insurance Companies.

7. That the following supporting documentation is annexed: (a) attested copy of CNIC of the undersigned; (b) certified copy of the policy and the schedule annexed thereto; (c) all premium-payment receipts; (d) loss intimation, claim form, and supporting claim documents; (e) the Insurer's repudiation / settlement letter dated insurer_decision_date; (f) all written communications with the Insurer; and (g) additional_documents.

8. That the undersigned seeks the following relief from the Federal Insurance Ombudsman: (a) declaration that the conduct of the Insurer constitutes maladministration; (b) direction to the Insurer to settle the claim in full in the sum of Rs. claim_amount (or balance of Rs. shortfall_amount); (c) payment of mark-up at markup_rate per annum on the unpaid claim from the date the claim ought to have been settled till realisation; (d) compensation for the inconvenience and consequential loss in the sum of Rs. compensation_claimed; (e) costs of the complaint; and (f) any other relief that the Federal Insurance Ombudsman may consider just and equitable.

It is, therefore, respectfully prayed that the Federal Insurance Ombudsman may be pleased to: (a) take cognisance of the present complaint; (b) summon the Insurer to file its written response with the entire claim file; (c) hold an inquiry into the conduct complained of; (d) afford the undersigned an opportunity to be heard; (e) determine the complaint on its merits and issue a binding order on the Insurer; and (f) communicate the outcome to the undersigned.

_____________________________ complainant_name Complainant CNIC: complainant_cnic Contact: complainant_contact