For some time now, the issue of whether a sales representative
can cross-position different insurance policies or financial
products through the mechanism of a multi-policy or multi-product
discount has been somewhat of a vexed issue – to say the
least.
In this context, we are referring to a scenario where a client
makes an enquiry about Product A (or an outbound call concerns
Product A), but there is a desire on the part of the relevant
financial institution to cross-position other products, to the
extent that this is legally achievable and compliant.
Of course, at one level, the reason that this has been a vexed
issue is because the new anti-hawking regime was designed to
prevent or impede so called cold-call cross-selling. On the one
hand, offering a client Product B, when the scope of the
interaction otherwise is related to Product A, has been seen
traditionally as infringing the anti-hawking prohibition. On the
other hand, an interaction which is centred
