Tag Archives: casualty

Traditional Insurance Is Dying

Finance. Taxis. Television. Medicine. What do these have in common?

They’re all on the long–and growing–list of industries being turned upside down by disruptive technology. 

The examples are legion. Once-sure-bet investments like taxicab medallions are at risk of going underwater. Bitcoin is giving consumers the power to bypass banks. Traditional television is at risk from online streaming.

Insurance Is No Different

In fact, innovative players have been disrupting the insurance market since before “disruption” was the buzzword it is today. 

Look at Esurance, which in 1999 rode the dot-com wave to success as the first insurance company to operate exclusively online. No forms, no policy mailers–it didn’t even mail paper bills.

By going paperless, Esurance told customers that it was the kind of company that cared about their preferences–and established itself as a unique player in an industry that places a premium on tradition. Insurance isn’t known for being innovative. 

Most insurance leaders operate under the assumption that if it ain’t broke, you shouldn’t fix it. And in a heavily regulated industry, that’s not totally unreasonable. 

But you only have to look at the scrappy start-ups that are taking down long-established players to understand what awaits the companies that aren’t willing to innovate.

Thinking Outside the Box

Take Time Warner–profit fell 7.2% last quarter as industry analysts foretold “the death of TV.” Meanwhile, Netflix’s profits are soaring beyond expectations–even as the risks it takes don’t always pan out. 

Remember the “Marco Polo” series that cost a reported $90 million? Neither does anyone else. But for every “Marco Polo” there’s an “Orange Is the New Black.” Highly successful programs on a subscription model show that Netflix’s willingness to take risks is carrying it past industry juggernauts.

The market is changing–and if you want to stay competitive, you need to use every weapon in your arsenal. Millennials aren’t buying insurance at the rate their parents did

To a consumer population weaned on technology like Uber and Venmo, the insurance industry seems positively antiquated. Facebook can advertise to you the brand of shoes you like–so your insurance company should be able to offer a product that you actually want.

The Information Importance

According to Accenture, “Regulated industries are especially vulnerable” to incumbents. When there are barriers to entry based on licensing requirements or fees, competition is lower. Decreased competition, in turn, leads to less incentive to innovate. This can leave regulated industries, such as insurance, healthcare and finance, in a highly vulnerable position when another company figures out a way to improve their offerings.

Other attributes that can make an industry vulnerable, per Accenture’s findings, can include:

  • Narrow focus: If a brand focuses entirely on cost savings, convenience or innovation, it isn’t effectively covering its bases. A disruptor that manages to offer two or three of these factors instead of just one has a near-immediate advantage.
  • Small scope or targets: Failing to expand offerings to all demographics can mean that industries or service providers aren’t able to replicate the broad reach of disruptors.
  • Failing to innovate: Disruptors don’t always get their product right on the very first try. Companies must innovate continuously and figure out ways to build continuous improvement into their business model.

Tech start-ups use information as an asset. How can you tell if information is a valuable weapon in the battle you’re fighting? 

“Big data” isn’t just a buzzword; industry analysts are calling it the wave of the future. At Citi, they’re talking about “the feed”: a real-time data stream that leverages the Internet of Things to reshape risk management. 

Auto insurers are turning to connected cars to let them reward safe drivers. Some life insurers are even offering discounts to customers who wear activity trackers.

It Can Happen to You

For most insurance companies, incorporating an unknown element into the way they operate is daunting. 

But talk to any cab driver, grocery store clerk or travel agent, and they’ll tell you that the only way to survive in a technology-driven world is to innovate.

Look at the insurance technology market to see what improvements you can incorporate into your organization, and think expansively about how you can use information: for agency management, to attract new customers and retain old ones, to expand your profit margins or to streamline operating costs. 

Your survival depends on it.

The Painstaking Saga Behind NARAB

On Jan. 9, I had the pleasure of sharing spontaneous drinks and dinner with José Andrés, Washington’s first and only international celebrity chef.

He had just launched China Chilcano, the latest in his burgeoning empire of restaurants, only three days old at the time, and was only a month away from opening yet another concept. He asked how I was doing, and I told him I’d had a great week—that a bill I’d been working on for literally 23 years at the Council (NARAB, attached to the TRIA extension), was passed by the Senate just the day before.

About then, another well-wisher approached José and congratulated him on his latest achievement. “Meet my friend Joel,” he says to the guy. “He’s either the best lobbyist I’ve ever met—or he’s the [worst].”

Rightly or wrongly, I’ve been majorly associated with NARAB (“National Association of Registered Agents and Brokers”) in its multiple iterations since the early 1990s. It’s not the biggest thing I’ve worked on by any stretch—the Terrorism Risk Insurance Act, the Affordable Care Act and Dodd-Frank are all far more important to the nation, our member firms and your clients. But NARAB has been the most painstaking.

We’ve snatched defeat out of the jaws of victory on so many occasions that it almost seemed preordained we’d lose again when TRIA failed in December. Facing implacable opposition to NARAB from retiring Sen. Tom Coburn, R-Okla., then-Majority Leader Harry Reid, D-Nev., pulled the plug on TRIA and adjourned the Senate for the year—astonishing all of us who’d worked so hard on the legislation.

Much of the blame at the time went to Coburn, as he was the only announced senator down the stretch with a “hold” on the TRIA/NARAB legislation, but the truth is more complicated, as there was considerable liberal discontent with the legislation. That’s all water under the bridge now.

Within a couple days of the disaster, House Speaker John Boehner, R-Ohio, and incoming Senate Majority Leader Mitch McConnell, R-Ky., both released strong statements saying they would put TRIA passage on the “early” priority list for January. Both kept their word.

Congress convened Jan. 6. The House bill passed in December was re-enacted Jan. 7, and the identical bill cleared the Senate Jan. 8. President Obama signed the bill into law Jan. 12. This followed critical leadership on the issue from Chairman Jeb Hensarling, R-Texas, of the House Financial Services Committee, and Sen. Richard Shelby, R-Ala., the new chairman of the Senate Banking Committee.

Now the work can begin to actually create NARAB—an interstate licensure clearinghouse for nonresident producer licensure. Decades of compromises to get the legislation to the finish line will now become complications you’ll hear about in the coming months. The governance of the body will come principally from state insurance commissioners and the National Association of Insurance Commissioners. Funding problems will emerge because no federal dollars or borrowing will be allowed. And there will be disagreements about the standards for NARAB membership.

The basic deal is this: Any producer first has to be properly licensed in his or her own state. Then on a purely optional basis, he or she can apply for membership in NARAB and meet whatever requirements are established. The applicant can then check off the states in which he or she needs a nonresident licensure, paying the applicable state fees. That all sounds really simple, but we’re sure in practice it will be akin to giving birth to a live squirrel.

The protracted lobbying effort initiated in 1992 by the Council’s forerunner organizations (the National Association of Casualty and Surety Agents and the National Association of Insurance Brokers) seems disproportionate. At its core, NARAB is simply an administrative mechanism to facilitate nonresident producer licensure. But since its inception NARAB has been caught up in the push and pull of the broader debates over federal-vs.-state insurance regulation. Many colleagues of mine are putting their children through college in this continuing war of attrition.

My own children, meanwhile, are nonplussed by the history of NARAB, but here it is anyway. First it was a purely federal option, as a part of now-retired Rep. John Dingell’s, D-Mich., insurer solvency legislation, which would have created an Optional Federal Charter for insurers. That went nowhere. Then we spun it off as a stand-alone and waged a lonely battle for years, culminating in the “NARAB 1” title of the Gramm-Leach-Bliley Act of 1999. To sneak it through Congress over the opposition of then-Sen. Phil Gramm (for months, my colleagues referred to me as “Dead Man Walking” on the assumption that Gramm would prevail), we had to dumb down the provision. If a majority of states passed reciprocal licensing laws, there would be no NARAB. So a majority of states did so, which was welcome. But it wasn’t enough.

In the past decade, the coalition of NARAB supporters has grown substantially, with other producer organizations and the NAIC itself moving from a position of opposition to strong support over the years. In that decade, NARAB passed the House on at least six occasions (I lose count), both as a stand-alone measure and as part of other reforms.

As we now move to implementation issues, I will pause to give thanks for the many in Congress who made this happen. Most recently, our champions and authors were Rep. Randy Neugebauer, R-Texas, Rep. David Scott, D-Ga., Sen. Jon Tester, D-Mont., and now-retired Sen. Mike Johanns, R-Neb. We can’t thank them enough. And I think back to the 1999 Gramm-Leach-Bliley debate, when Rep. Sue Kelly, R-N.Y., and the late Sen. Rod Grams, R-Minn., fought so hard for NARAB.

I guess it’s easier to be gracious in victory, but we wish all the best for Sen. Coburn, who did everything he could to beat NARAB. I regarded him as an obstinate SOB for many months, but he always acted out of his own federalism principles. He retired from the Senate when his cancer recurred, and we have high hopes he can beat it. Because he’s just that obstinate.

This article first appeared in Leader’s Edge magazine.

What Microsoft’s Errors Can Teach Us

What would it take to convince people that your business delivers a great customer experience? For tech giant Microsoft, the answer was more than $1 billion.

That’s how much the company reportedly spent on its Windows 8 marketing campaign when the new operating system was launched in 2012. (See, for example, “Microsoft Betting BIG On Cloud With Windows 8 And Tablets,” Forbes, Oct. 11, 2012.)

And how’d that work for them? Not so well. Windows 8 sales were underwhelming at launch, garnering far less market share than Windows 7 at the same point in its release cycle. So, what went wrong?

In a word, it was the experience of using Windows 8. The software was designed to support both touchscreen tablets and traditional desktop PCs, but it handled neither particularly well. Many software reviewers and design gurus found the Windows 8 interface just plain confusing. One even declared that it “smothers usability” (Jakob Nielson of Nielsen Norman Group, Nov. 19, 2012, article titled “Windows 8 — Disappointing Usability for Both Novice and Power Users.”)

But this isn’t a story about the usability of a new software program. It’s a sobering reminder that great, loyalty-enhancing customer experiences — the kind that get people talking and buying — can’t be created with Super Bowl ads, stadium naming rights, public relations blitzes or any type of advertising campaign.

Those marketing instruments may help pique people’s interest in what you have to offer, but it’s the actual interactions they have with your company — the customer experience itself — that will ultimately drive long-term engagement.

Microsoft isn’t the only organization that’s erred in this regard. Many companies, across many sectors, try to use their marketing muscle to win the hearts and minds of consumers. The property/casualty industry spent more than $6 billion on advertising in 2013, according to research firm SNL Financial. And that’s just the carriers. It doesn’t include marketing expenditures by agents and brokers that, albeit smaller in absolute terms, are nonetheless material expenses for many field offices.

Some in the industry would argue that these are necessary expenditures, required elements for raising brand awareness and consideration among one’s target market.

That’s a fair statement, but in reality what often happens is that the marketing of a company’s brand promise gets far more attention than the fulfillment of that brand promise. And it’s that disconnect for customers that will undermine even the most carefully orchestrated branding campaigns, as Microsoft learned.

How can you help your organization avoid this kind of misstep?

Use the three tips below to reconsider what it really means to manage your company’s brand experience:

1. Think about brand in a brand new way.

If the term “brand management” conjures up images of your chief marketing officer or advertising agency, then it’s time to think more broadly. People’s impressions of a company’s brand will be shaped by the totality of interactions they have with the firm.

Granted, some of those interactions will be more influential than others, but they all serve to shape customer perceptions in some fashion.

Companies that cultivate intense customer loyalty recognize the broad array of touch points that compose their brand experience. And they actively manage those touch points to create great, even legendary, brand impressions.

For them, brand is about much more than a billboard, radio spot or TV advertisement. It’s about the end-to-end experience, from pre-sale to post-sale. It’s about their website, their call center, their retail outlets, their customer correspondence, even their billing statements. Every live, electronic or print interaction you can imagine.

Case in point: Amazon.com’s obsession with packaging. The online retailer, perennially rated among the most loved brands in any industry, obsesses over every detail of their brand experience, right through and including the act of opening up the box they send you.

Amazon recognizes that, even if subconsciously, the mere act of opening up a package will necessarily influence customers’ perceptions about the purchase process. And so they’ve tried to make even that as easy as possible by introducing “frustration-free” packaging that eliminates metal twist ties, razor-sharp plastic clamshells and other annoying wonders of modern packaging.

As a result, it isn’t just buying from Amazon that’s effortless (thanks to their patented one-click purchase button), so, too, is opening the package they send you. That’s what end-to-end management of the brand experience looks like in practice.

Think of all the customer interactions that will either reinforce your company’s brand promise or undermine it: coverage quotes, sales proposals, insurance applications, policy contracts, loss control programs, renewal communications, premium audits. The list goes on and on.

No matter what you choose to have your brand stand for — simplicity, expertise, helpfulness, sophistication, expediency or some other attribute — ask yourself if that theme truly permeates your company’s brand experience, and not just its advertising. If it doesn’t, remedy that by better balancing investments in promoting your brand promise with investments in actually fulfilling it.

2. Don’t just say it, prove it.

Talk is cheap when it comes to brand promises.

Any company can claim through its marketing to be something that it isn’t: fast, friendly, knowledgeable, client-focused, easy to do business with. What ultimately matters to customers isn’t what you say but what you do.

The most compelling brand promises are those that are backed up with tangible proof points — things that demonstrate very clearly to customers (or prospects) that your business really walks the talk.

Take Southwest Airlines, a company that aims to make air travel a bit friendlier, fun and hassle-free. Among the proof points: warm, personable staff and no baggage fees.

Or Trader Joe’s, a company that’s sought to make the grocery-shopping experience less overwhelming. (How many varieties of ketchup does the world really need?) Proof point: The company stocks shelves with just a fraction of the number of SKUs carried by competitors, each carefully selected based on target consumer tastes.

Patagonia, a maker of outdoor clothing and gear, has marketed itself as an environmentally responsible company. Proof points: The company uses organic cotton — and even recycled soda bottles– to make clothing and also donate 1% of revenue (sales, not profit) to environmental organizations.

All three companies are beloved by their customers, in part because people know what these organizations stand for and see them delivering on their brand promise in very demonstrable ways.

Does your company’s brand promise pass the “proof point” test?

Consider what your firm has chosen to be famous for, what brand attributes you’ve claimed, and then ask yourself: What could you point to that proves it?

If you’re at a loss to identify some tangible proof points, start creating some. Look at your customer touch points through the lens of your brand promise — coverage quotes, applications, policy documents, correspondence, premium audits, etc. Think about how those touch points could be reshaped (or new ones added) to help bring your brand message to life during routine interactions with customers.

And even if you are able to identify some existing proof points, it’s worth asking: Are you adequately highlighting them in your marketing campaigns? You might be aware they exist, but your customers and prospects might not. Don’t keep them a secret. Follow the lead of companies like Southwest, Trader Joe’s and Patagonia and show the marketplace that your organization’s claim to fame is anything but hollow.

3. Don’t sabotage your sales.

While you can’t advertise your way to a great customer experience, you can at least hope to fill your sales pipeline via those marketing efforts.

But even that marketing investment is pointless if it’s not easy for people to comprehend and buy your products. The purchase experience is an integral part of the customer experience. Sales interactions are as important to shaping your brand as service interactions.

Yet companies often sabotage their sales (and undermine their marketing efforts) by making it difficult for people to buy their products. From poorly staffed retail stores to ill-equipped telephone sales reps to unnavigable websites, businesses erect obstacles that exhaust even the most interested prospects.

BlackBerry, a company that dominated the mobile handset business for years, learned this the hard way as its product portfolio burgeoned and sales process became increasingly complex.

The inflection point came around 2011, when consumers who visited BlackBerry’s website were met with a wall of more than 20 device images– all with confusingly similar names (Bold 9780, Bold 9700, Bold 9650, etc.)– presented on a black screen that made it difficult to even see the devices. Plus, the site offered no “electronic wizard” to help prospective purchasers narrow down the handset selection based on how they intended to use the device.

Contrast that with what visitors to Apple’s iPhone website saw: just three smartphones, presented on a beautiful, bright and transparent background, making it easy to not just discern the devices but to choose the one that best met their needs.

Comparing these two product purchase experiences, is it any wonder that Apple’s handset business thrived while BlackBerry’s stumbled?

Oftentimes, it’s not the best product that wins in the marketplace but rather the one that’s most easily accessible and understandable to the customer. Our brains are wired for the path of least resistance. The more thought and energy required to navigate the purchase process, the more likely it is that people will just abandon the effort — and buy something that’s less taxing on their minds.

Maximize the effectiveness of marketing programs by carefully shaping the customer experience — long before they’re a customer. How easily can prospects navigate your product portfolio? Comprehend product features? Interpret a sales proposal? Get purchase guidance when they need it?

These are the questions you should be asking to create a purchase experience that not only burnishes your brand but also turns more prospects into customers.

No matter what you’re selling, the real battle for people’s hearts and minds isn’t waged on billboards and airwaves. Marketing campaigns may provide air cover, but the hand-to-hand combat of each customer interaction is where true loyalty is forged — the simplicity of your sales process, the usability of your products, the clarity of your communications, the helpfulness of your staff, etc.

So, before you hang your hat on an expensive marketing campaign to convince people how wonderful your product or service is, ask yourself why they need convincing at all.

This article first appeared at Carrier Management.

The Basic Problem for Health Insurance

The health insurance market is changing. And the changes are not good. Even before there was Obamacare, most insurers most of the time had perverse incentives to attract the healthy and avoid the sick. Now, the perverse incentives are worse than ever.

Writing in the New York Times, Elizabeth Rosenthal gives these examples:

  • When Karen Pineman of Manhattan sought treatment for a broken ankle, her insurer told her that the nearest in-network doctor was in Stamford, Connecticut – in another state.
  • Alison Chavez, a California breast cancer patient, was almost on the operating table when her surgery had to be canceled because several of her doctors were leaving the insurer’s network.
  • When the son of Alexis Gersten, a dentist in East Quogue, NY, needed an ear, nose and throat specialist, the insurer told her the nearest one was in Albany – five hours away.
  • When Andrea Greenberg, a New York lawyer, called an insurance company hotline with questions she found herself speaking to someone reading off a script in the Philippines.
  • Aviva Starkman Williams, a California computer engineer, tried to determine whether the pediatrician doing her son’s two-year-old checkup was in-network, and the practice’s office manager “said he didn’t know because doctors came in and out of network all the time, likening the situation to players’ switching teams in the National Basketball Association.”

But aren’t these insurers worried that if they mistreat their customers, their enrollees will move to some other plan? Here’s the rarely told secret about health insurance in the Obamacare exchanges: Insurers don’t care if heavy users of medical care go to some other plan. Getting rid of high-cost enrollees is actually good for the bottom line.

To appreciate how different health insurance has become, let’s compare it with the kind of casualty insurance people buy for their home or their cars.

Dennis Haysbert is the actor I remember best for playing the president of the U.S. in the Jack Bauer series, 24.  You probably know him better as the spokesman for Allstate. In one commercial, he is standing in front of a town that looks like it has been demolished by a tornado. “It took only two minutes for this town to be destroyed,” he says. He ends by asking, “Are you in good hands?”

The point of the commercial is self-evident. Casualty insurers know you don’t care about insurance until something bad happens. And the way they are pitching their products is: Once the bad thing happens, we are going to take care of you.

Virtually all casualty insurance advertisements carry this message, explicitly or implicitly. Nationwide used to run a commercial in which all kinds of catastrophes were caused by a Dennis-the-Menace type kid. In a State Farm ad, a baseball comes crashing through a living room window. Nationwide’s “Life comes at you fast” series features all kinds of misadventures. And, of course, the Aflac commercials are all about unexpected mishaps.

My favorite casualty insurer print ad is sponsored by Chubb. It features a man fishing in a small boat with his back turned to a catastrophe. He is about to go over what looks like Niagara Falls. Here’s the cutline: “Who insures you doesn’t matter. Until it does.”

Now let’s compare those messages with what we see in the health insurance exchange. Federal employees have been obtaining insurance in an exchange, similar to the Obamacare exchanges, for several decades. Every fall, during “open enrollment,” they select from among a dozen or so competing heath plans. In Washington, DC, where the market is huge, insurers try to attract customers by running commercials on TV, in print and in other venues.

If the health insurers followed the lead of the casualty insurers, their ads would focus on what could go wrong and how good they are at treating the problems. After all, why do you need health insurance? Because you might get cancer, heart disease or some other expensive-to-treat condition. And when that happens, you would like to be in a plan that give you access to the best doctors and the best facilities for your condition.

In fact, this is what you never see in a health insurance commercial in Washington, DC. There is never a mention of cancer, heart disease, diabetes, AIDS or any other serious health condition.  Instead, what you see are pictures of young healthy families. The implicit message is: If you look like the people in these photos, we want you.

What explains the difference between the health insurance and casualty insurance markets? In the latter, people pay real prices that reflect real risks. In the former, no one is paying a premium that reflects the expected cost of his care. The healthy are being overcharged so that the sick can be undercharged. So, insurers try to attract the healthy and avoid the sick.

The perverse incentives don’t end after enrollment. The incentive then is to under-provide to the sick (to encourage their exodus and avoid attracting more of them) and over-provide to the healthy (to keep the ones they have and attract even more).

Rosenthal explains what this means for people who need care:

“For some, like Ms. Pineman, narrow networks can necessitate footing bills privately. For others, the constant changes in policy guidelines — annual shifts in what’s covered and what’s not, monthly shifts in which doctors are in and out of network — can produce surprise bills for services they assumed would be covered. For still others, the new fees are so confusing and unsupportable that they just avoid seeing doctors.”

So what’s the answer? In a previous post, I argued that we can denationalize and deregulate the exchanges. And by instituting “health status insurance,” we can have a market with real prices that gives real protection to people with pre-existing conditions.

There is no reason why the health insurance marketplace cannot work just as well as the market for homeowners insurance and auto liability insurance.

This article originally appeared at Forbes.

Owner Controlled Insurance Program Liability Claims Challenges, Part 8

This is the eighth article in an 11-part series on Owner Controlled Insurance Programs. Preceding and subsequent articles in this series can be found here: Part 1, Part 2, Part 3, Part 4, Part 5, Part 6, Part 7, Part 9, Part 10, and Part 11.

Particular Challenges Of Owner Controlled Insurance Program Claims

Uncovered Damages
Under a typical general liability policy, if a claim presented against an “insured” is partially covered by the policy, the insurance carrier issues a reservation of rights. The reservation of rights letter identifies those claims, causes of action, or damages that are not covered by the policy. The insurance carrier also notifies the insured whether it will defend and whether it will allow the insured to use its choice of counsel in doing so. Significantly, however, where the insurance company does not agree to indemnify the insured for all claims and damages, the insured retains the right to pursue other responsible parties to recover those sums. In the liability Owner Controlled Insurance Program, there are two consequences of reserving rights to deny uncovered claims.

First, in underwriting an Owner Controlled Insurance Program, the insurance company hopes to enjoy cost savings by using a limited number of attorneys to defend the enrolled contractors against claims by the sponsor or by a third party. If the carrier reserves its rights to, however, it is possible, and indeed likely, that the enrolled subcontractor will seek recovery from other enrolled subcontractors under indemnity contracts. The indemnity claims a conflict preventing the retention of a single defense counsel. Second, each enrolled contractor has a right to pursue indemnity claims against other enrolled contractors for covered and uncovered claims.

Therefore, in a complex liability claim presented against the general contractor and/or several subcontractors, the insurance company must recognize early the potential for conflict between the enrolled contractors and the likely value of the uncovered claims.

Post Construction Premises Claims
In numerous Owner Controlled Insurance Programs, the sponsors request products-completed operations coverage for a period of time after construction. Premises liability claims arising after construction of the project create a particular challenge to underwriters attempting to limit their risk to construction-related liability. A typical extension endorsement provides coverage for liability occurring after construction and arising out of the construction. Under California and most states’ laws, the term “arising out of” connotes a minimal causal connection between the liability and the construction activities. Acceptance Insurance Company vs. Syufy Enterprises (1999) 69 Cal.App.4th 321. An additional insured endorsement requiring that liability “arise out of” the subcontractor’s work needs only a minimal causal connection between the subcontractor’s work and the liability of the additional insured to trigger coverage.

In a premises liability claim, the claimant alleges that the ground is slippery, uneven, or otherwise defective. In fact, in order to establish liability against the landowner, the plaintiff must establish that the premise is defective in some fashion. Accordingly, it is very likely that a premises liability claim will at least implicate a products-completed operations tail under an Owner Controlled Insurance Program. In large projects where the owner is self-insured, such as large hotels or public entities, it is likely that the only insurance coverage will be the Owner Controlled Insurance Program. An insurer may not seek contribution from its insured nor may it seek contribution against a carrier with a self-insured retention. (Truck Insurance Exchange vs. Amoco Corporation (1995) 35 Cal.App.4th 814.) Accordingly, notwithstanding that there may be both a “condition” component of the loss as well as a “maintenance” component of the loss, there may be a more significant exposure to the Owner Controlled Insurance Program than the underwriters contemplated.