companies have started to offer professional advice to companies about the adequacy of their insurance cover.

But the industry needs to develop further its actuarial capabi ties and to compile more complete and reliable data on loss experience. There is also a need to develop mortality tables that cover the population of insured Tunisians. Closer and more extensive technical cooperation of insurance companies, perhaps under the aegis of the insurance association, would be helpful in this respect, although the law should ban any collusion on the setting of premiums or the introduction of new products.

# **Consumer Pkotection**

The insurance code contains several provisions that aim to enhance the protection of consumers. But some of these provisions threaten to have an inhibiting effect on the growth of the industry, either by making more difficult the recruitment of agents and salesmen or by increasing the bureaucratic costs of doing business.

With regard to the minimum professional qualifications, the authorities should consider relaxing the recently ihtroduced criteria and allow staff with one year's training and an aptitude to sell insurance to be hired as salesmen. Not every salesman of insurance needs to have a university degree in mathematics and to be an actuary. Provided the products are well designed and provided the salesforce receives adequate back-office support, persons with less extensive education but with a satisfactory minimum amount of training could be allowed to qualify.

The use of detailed forms that may be difficult to comprehend offers little protection to consumers. The authorities could consider instead the creation of an insurance ombudsman office that would be responsible for investigating consumer complaints and order insurance companies to settle disputes if the complaints are justified. Consumers should retain the right of redress through the courts. The ombudsman office could be operated under the aegis of the association of insurance companies.

# **Industry Dialogue**

At present, it is not clear that there is a sufficient dialogue between representatives of the insurance companies and the authorities. A more effective dialogue could be promoted by the association of insurance companies, which in any case needs to develop a more independent profile and to represent the views of the industry. The association may also undertake publicity campaigns to educate the public in insurance matters and to improve the public image of the industry.

# **Training Programs**

The modernization and development of the insurance industry would require a major effort in training that should encompass not only actuaries, financial analysts, investment managers and selling agents, but also insurance supervisors and examiners. There is already a well functioning insurance course run by IFID, but this needs to be complemented with more intensive courses, especially for actuaries and supervisors. Allowing foreign companies to enter the Tunisian market will provide a major channel for training local staff. The training of supervisors and examiners should be based on closer cooperation with supervisory authorities in OECD countries, especially the neighboring European countries.

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