On 19 September 2019, the China Banking & Insurance
Regulatory Commission ('CBIRC') publicly circulated
('Circular') a list of endemic problems CBIRC had
identified during the course of its recent investigation and
supervision of certain life and health insurance products
('Product Defects') manufactured by certain named insurance
companies ('Monitored Insurers'). The Circular requires the
Monitored Insurers to make conscientious rectification of the
Product Defects, and to strive assiduously to improve their
internal product management processes.
The Circular states that the Product Defects are largely centred
around the manner in which Monitored Insurers go about registering
and filing their new insurance products with CBIRC
('Registration'). Specifically identified Product Defects
include (i) the large number of new Products which, after
successful Registration, are then not released into the market at
all, or, if released, achieve dismally low sales numbers; (ii)
