TPP CHALLENGES AND OPPORTUNITIES FOR VIETNAM’S INSURANCE INDUSTRY

MINISTRY OF EDUCATION AND TRAINING FOREIGN TRADE UNIVERSITY DISSERTATION TPP: CHALLENGES AND OPPORTUNITIES FOR VIETNAM’S INSURANCE INDUSTRY Major: International Trade Policy and Law Full name: Nguyen Thuy Binh Hanoi - 2017 MINISTRY OF EDUCATION AND TRAINING FOREIGN TRADE UNIVERSITY DISSERTATION TPP: challenges and opportunities for Vietnam’s insurance industry Major: International Trade Policy and Law Full Name: Nguyen Thuy Binh SUPERVISOR: Dr Nguyen Binh Minh Hanoi - 2017 DECLARATION I declare that this dissertation is my own work Where material is obtained from other works, it has been fully acknowledged by citation in the main text and included in the references TABLE OF CONTENTS INTRODUCTION .1 CHAPTER OVERVIEW OF VIETNAM INSURANCE INDUSTRY 1.1 History of Vietnam’s insurance industry 1.2 Overview of life insurance industry 1.3 Overview of non-life insurance industry 14 CHAPTER TPP’S OVERVIEW AND VIETNAM’S INSURANCE COMMITMENTS IN TPP .21 2.1 TPP’s overview and commitments in insurance industry 21 2.2 Current regulations and legislation of Vietnam relating to insurance 25 2.3 Vietnam’s insurance commitments in TPP .30 CHAPTER CHALLENGES AND OPPORTUNITIES FOR VIETNAM’S INSURANCE INDUSTRY AFTER EFFECTIVENESS OF TPP .40 3.1 Challenges for Vietnam’s insurance industry 40 a Challenges for life insurance industry .40 b Challenges for non-life insurance industry .44 3.2 Opportunities for Vietnam’s insurance industry 52 a Opportunities for life insurance industry 52 b Opportunities for non-life insurance industry 54 CHAPTER VIETNAM’S PREPARATION FOR TPP & RECOMMENDATIONS FOR VIETNAM 65 4.1 Preparation of Vietnam 65 a Preparation of Vietnam’s authority 65 b Preparation of Vietnam’s local insurers 68 4.2 Recommendations for Vietnam 72 a Recommendations for Vietnam authority 72 b Recommendations for local insurers 74 CONCLUSION 77 REFERENCE 81 LIST OF ABBREVIATION TPP: MOF: The Transpacific Partnership Agreement The Vietnam Ministry of Finance LIST OF FIGURES Figure 1.1 Vietnam Life Insurance indicators Figure 1.2 Vietnam Life Insurance Market share in first quarter of 2016 .10 Figure 1.3 Year of establishment of Life Insurers and charter capital (billion dong) in 2013 .11 Figure 1.4 Policy numbers by products in 2015 13 Figure 1.5 Types of life products by insurer in 2015 .14 Figure 1.6 Vietnam Non-Life Insurance indicators 14 Figure 1.7 Vietnam Non-Life Insurance Market share in first quarter of 2016 .15 Figure 1.8 Year of establishment of Non-Life Insurer and charter capital (billion dong) in 2013 16 Figure 1.9 Types of non-life products by insurer in 2015 .18 Figure 1.10 Non-life loss ratio in 2014 19 Figure 3.1 Insurance Premium Growth Rate (2013) 46 Figure 3.2 Insurance penetration rate for TPP countries 47 Figure 3.3 ACE gross premium for developing TPP countries .47 Figure 3.4 Impact of TPP on sectoral output by 2030 .49 LIST OF TABLES Table 1.1 Vietnam indicators in comparison with ASEAN countries and world in 2015 .8 Table 1.2 Numbers of life insurers .9 Table 1.3 Numbers of non-life insurers 15 Table 1.4 Vietnam’s non-life agents 17 Table 2.1 Comparison of insurance cross-border trade in WTO and Vietnam’s domestic law 28 Table 3.1 Trade and investment effects of TPP (Unit: billions of 2015 dollars) .57 Table 3.2 Importing cars of Vietnam in October 2016 61 INTRODUCTION Research background Regional integration has become a new trend in the Asia- Pacific region, which represents in the form of treaties The Trans-Pacific Partnership Agreement (TPP) was one among of those treaties TPP is a multilateral free trade agreement, which aims to create a free trade zone among Asian – Pacific countries Singapore, Chile, New Zealand, Brunei was the founders of this Agreement They had signed the TPP since June 2005 However, until present the member number of TPP has expanded up to 12 countries, including: Singapore, Chile, New Zealand, Brunei, United States, Australia, Canada, Japan, Malaysia, Mexico, Peru, and Vietnam In TPP, member countries commit to open their market by tariff reduction, non-tariff measure transparency, market access barrier elimination for foreign companies from other member countries etc For example, USA will remove tariff for 74 percent of Vietnam exporting agriculture goods upon TPP’s effective date and for 100 percent of goods after 10 years of TPP implementation 38.4 percent of Vietnam agriculture goods exporting to Japan will be eliminated upon TPP’s implementation and 100 percent of goods exporting to Japan will be exempted from tax after 15 years (Duy Anh, 2015) Given those tariff reduction, Vietnam will be benefited by increase in exports to those major markets In addition, foreign investment into Vietnam will surge thanks to TPP Besides the above benefits, Vietnam also have market opening commitments, bringing big challenges to domestic companies, whose competitiveness is still quite low One of those commitments refers to insurance market Since Vietnam’s insurance industry is among the youngest insurance markets in the world The first non-life insurance company of Vietnam was established just 51 years ago and of life insurance company was 20 years ago, compared to hundreds-year companies in other developed countries, such as: USA, Canada, Japan etc Therefore, it is predicted that Vietnam’s insurance industry will face tough challenges from competition of foreign insurers Of course, there will be opportunities for Vietnam’s insurance industry from TPP However, those challenges and opportunities is still a controversial topic At the inception date of this research, TPP is highly likely to be implemented by 12 member countries Until now, the United States had changed its president (i.e.: Donal Trump), who strongly opposes TPP Therefore, this agreement is predicted to be canceled Despite of this fact, the value of this thesis is not reduced The reason is that international integration is an undeniable trend of the world Besides TPP, Vietnam is on the way to participate in similar multilateral free trade agreements Therefore, sooner or later Vietnam’s insurance industry shall face similar challenges and opportunities brought by TPP This research will give readers an understanding of impacts that TPP and future multilateral treaties may bring to Vietnam’s insurance industry Literature review From the very beginning of first discussion round, Vietnam’s insurance commitment in TPP had attracted attention from local and foreign media, researchers From foreign writers, TPP’s impact to Vietnam was a hot topic for foreign newspaper and researchers However, those articles and studies examined the impacts of TPP in general The impact of insurance to Vietnam received smaller attention from foreigners This topic had been analyzed on some foreign newspapers, e.g.: the Insurance Journal of Canada, which discussed about the potential of Vietnam insurance market thanks to TPP It was also assessed by foreign insurers, e.g.: ACE Group had published a small analysis named “TransPacific Partnership: Unlocking new opportunities” However, it was very hard to find an academic research of this topic Some of them is working paper titled “The Economic Effects of the Trans-Pacific Partnership: New Estimates” e.g.: by Peter A Petri and Michael G Plummer in January 2016 But TPP’s impacts to Vietnam insurance market was a very small part of the working paper From domestic writers, there were more articles discussing the impacts of TPP to Vietnam’s insurance market, including: newspapers, conference, discussion papers Some local newspaper e.g.: Vietnamnet, Financial News of Vietnam, had quite valuable analysis of this topic Besides those newspaper, some conferences were held by competent authorities for the discussion of this topic Take example of the Conference named “Opportunities, Challenges of TPP and new generation FTAs to Vietnam’s insurance industry” held by the Vietnam Insurance Association and Vietnam International Arbitration Center on 16 May 2015 This conference had participation of some insurance specialists, which contributed their discussion papers to the conference, i.e.: “TPP and challenges to Vietnam’s insurance industry” of Master Ton Thi Thanh Huyen from National Economics University and “Impact of TPP to Vietnam’s insurance industry” of Doctor Nguyen Binh Minh from Foreign Trade University Those two university are among top colleges in Vietnam in terms of finance Therefore, their discussion papers are more argumentative academic than newspaper articles However, until now there has not been a comprehensive, large-scale research of this topic of the local Some research had analyzed the impacts of TPP to Vietnam in general, e.g.: dissertations However, there is absence of study focusing only on impacts of TPP to Vietnam’s insurance industry This thesis will concentrate on the analysis of TPP’s effects on insurance industry only Subject of the research This thesis aims at the impacts of TPP on Vietnam’s insurance industry, including the impacts on life and non-life insurance Scope of the research This thesis will not study all articles of TPP Instead of that, it will only analyze articles related to Vietnam’s insurance industry, which are included in Chapter 11 and Annex III of the TPP While examining those TPP’s articles, this thesis will also study Vietnam’s current legal documents regulated insurance activities (e.g.: Law on Insurance Business 2000, WTO agreement) in order to make comparison between those documents and TPP as well as take research of Vietnam’s insurance industry situation including life and non-life insurance market Research question This thesis will answer a question: “What opportunities and challenges will TPP bring to Vietnam’s insurance industry?” In order to find the answer, this study will Firstly, analyze insurance commitments that Vietnam made in TPP in comparison with current legal framework in order to highlight the new regulations in TPP Secondly, examine the impacts of those new regulations to Vietnam’s insurance industry, including opportunities and challenges Some recommendations for local insurers and authority will be given at the end of the thesis to help the local utilizing those opportunities and overcome challenges Methodology In order to achieve the above purpose, this thesis will employ qualitative research methodology Particularly, this research will examine legal documents, make comparison between different legal documents, gather insurance data, and make analysis from those data Research structure This thesis comprises of chapters, which are: Chapter 1: Overview of Vietnam’s insurance industry Chapter 2: TPP’s overview and Vietnam’s insurance commitments in TPP Chapter 3: Challenges and Opportunities for Vietnam’s insurance industry after effectiveness of TPP Chapter 4: Vietnam’s preparation for TPP and Recommendations for Vietnam CHAPTER OVERVIEW OF VIETNAM INSURANCE INDUSTRY 1.1 History of Vietnam’s insurance industry In 1964 Vietnam Insurance Company was established, which is the first insurance company in the North of Vietnam, providing transported goods insurance, hull insurance and accident insurance for passengers travelling in Vietnam The establishment of Vietnam Insurance Company had opened an era of insurance monopoly in Vietnam Until 1979 – 1980, accident insurance for passengers was actually brought to the market The main target of this company was to support the foreign trade, therefore, it had remained a very low insurance rate, making the company suffering from loss at some times Besides the insurance providing, this company was in charge of cooperating with state trade agencies, transporting agencies to prevent and minimize the loss to transported goods and hulls From 1966, the company started to reinsure to foreign insurance companies based outsides of Vietnam By contrast, in the South, there was 41 domestic insurance companies and 10 foreign companies Among them, Vietnam Assurance and Reinsurance company (VAR) was the biggest company, accounting for 51% insurance contracts in the South (Baoviet, 2015, p.65) This company was a joint venture among Vietnam, French and Swiss In 1975, Spring Offensive was successful The North and the South were unified and both were under control of Vietnam Vietnam authority requested all insurance companies in South to end their business All assets of those companies were given to Vietnam Insurance and Reinsurance company – BAVINA (Baoviet, 2015, p.66) – a state company established in 1976 After that, in 1977, BAVINA became a branch of Vietnam Insurance Company according to Decision No 61 of Government Therefore, Vietnam insurance market was still state monopoly On 18 December 1993, Decree No 100/CP was enacted, allowing the establishment of joint venture companies, joint stock companies and 100% foreign competitiveness since WTO accession It will help local insurers to well prepare for the TPP effectiveness 4.2 Recommendations for Vietnam a Recommendations for Vietnam authority Given TPP comes into force, demand of both life and non-life insurance is predicted to surge This is great opportunity for local insurers to expand their business However, to grasp this opportunity, it requires some efforts from local insurers and the support of the competent authorities - Continue to review legal framework and revise where necessary in order to align with TPP as well as future FTAs Regarding insurance, Vietnam’s legal framework currently has met basic obligation in TPP There are some regulations needed to revise to align with TPP (e.g.: the cross-border trade regulation) and some to implement additionally (i.e.: the auxiliary services to insurance) However, it is more important for Vietnam authority to consider the overview picture during the law revision process At present time, only Japan had ratified TPP internally The main member of this agreement, which is USA, is considering to withdraw from the agreement The reason is that new president of USA does not support this FTA since it may have bad impacts on the employment of the local This poses a high risk to the implementation of TPP because the presence of USA in this agreement is very crucial Without USA, other members may be not interested to ratify this agreement, including Vietnam According to Vietnam’s Prime Minister: “The United States has announced it suspends the submission of TPP to the parliament so there are not sufficient conditions for Vietnam to submit its proposal for ratification” (Ho Binh Minh, 2016) Therefore, TPP agreement may be canceled However, in the long term, Vietnam will participate in another FTAs with obligations similarly to TPP As the results, it is still best to take preparation in 72 advance In another word, even though TPP may be collapsed, Vietnam still should to review insurance legal framework and make revision where necessary to prepare for the signing of future FTAs like TPP - Continue and tighten the insurance fraud controls and the compliance check of local insurers in order to promote a healthy sustainable insurance market Although Vietnam competent authority is applying several measures to control insurance fraud, for example: stipulate sanction for insurance fraud in Criminal Code, or regularly update the insurance fraud situation with Insurers, however, the number of insurance fraud is still high And insurance fraud is still a big problem to insurers, especially non-life insurance company According to information from Baoviet – which is the biggest insurers in terms of health and accident market shares, i.e.: 30 percent of market share, Baoviet has suffered from business losses due to insurance fraud of this product The high loss ratio of this product was alarming high The insurance fraud occurred not only from the bad intention of the insurance purchasers but also the collusion between the insurance purchasers and hospitals Until now, the company still has not found a best solution for this problem Therefore, it is suggested that Vietnam authority should support insurers more actively to minimize those fraud For example: the MOF can cooperate with insurers to investigate several insurance fraud cases and apply the sanction strictly to prevent similar fraud; or the Insurance Association of Vietnam can work with insurers to run campaigns in order to raise the customer’s awareness of insurance fraud and the consequences in case of fraud commit Beside the insurance fraud controls, Vietnam authority should continue to check the law compliance of insurers to ensure that they business subject to regulations Moreover, it is suggested that the Insurance Supervisory Agency could develop a cross check mechanism to support the check of the agency In particular, each insurer will play the role of a supervisor, in case it found error of another insurers, it will report to Insurance Supervisory Agency The Insurance Supervisory 73 Agency will need a punishment mechanism to penalize insurers, who not follow the law Only by that way, Vietnam can eliminate the situation, in which insurers compete each other by reducing premium without considering of the claim payment ability in case of accident occurred By this way, Vietnam will promote a healthy insurance market where insurers compete by their services and product qualities, but not by tricks It will benefit both insurers and the consumers b Recommendations for local insurers - Apply more information technology in operation to enhance the business efficiency Particularly, local insurers should develop a central-data management system to control data efficiently and design applications to replace manual processes (e.g.: underwriting, claim handling etc.) Although in recent years, local insurers have invested more in information technology, for example: developing trading online system, or upgrading website etc However, in general, the operation of local insurers are mainly done manually The customer database is not managed centralized and synchronized through all products For example: Baoviet has only one programme to control customer database of health insurance For other products, the consolidation are temporarily made manually by office tools (i.e.: excel office) Therefore, it is strongly recommend that local insurers should invest more in apply information technology for operation process In particular, local insurers should: Firstly, develop a central-data management system to control data With the help of technology to consolidate customer data centrally, insurers will have enough data to correctly calculate risks and work out appropriate premium to cover the risks Secondly, design applications to replace manual processes Particularly, they may apply technology in processing operational works, for example: an underwriting program which can automatically make suitable pricing based on questionnaire provided by insurance purchasers This model is quite common in some developed insurance market, e.g.: USA Similarly, a claim handling program should be 74 developed to help insurers automatically classify the claim types and suggest the claim payment Those applications will help insurers to (i) prevent human errors, cut down paper work as well as employees to reduce costs, (ii) speed up the processing time to serve more customers When the market demand of insurance increases, insurers will have to deal with an enormous amount of requests Therefore, automatic operational process based on technology is the key for insurer’s success - Concentrate in improving competences of the actuary staff Currently, local insurers, especially non-life insurance companies, are facing a problem of lacking skilled actuaries Premium is calculated based on experience and market preferences, rather than on data-based calculation Local health insurance market could be a good example Small insurers will follow the product structures, wording and even premium of bigger insurers It is not difficult to find that the health insurance product of local insurers are similar to each other Some insurers even copies exactly the products of other insurers to offer to the market This is the consequence of actuary lacking in local insurance company Developing actuary force is very important to insurers because they will help the company to calculate the appropriate premium to cover the risks It will ensure the business of insurance company will be profitable and insurers can cover the claims in case of losses occurred Moreover, given the TPP or any future FTAs, demand of new insurance products will be likely to occur, especially: types of liability insurance Therefore, local insurers will have to research and develop new products Without good actuary force, the task could not be done Therefore, improving competences of employees, especially actuary force is necessary for the long term growth of insurers - Focus on product and service quality improvement instead of product prices 75 The insurance market for individuals are getting more attention from local insurers due to its high potential Given the TPP comes into force, living standard of individuals will increase with the improvement of income It will make the individual market even more attractive This requires local insurers to change the business strategy into product and service quality enhancement At the present time, local insurers especially in non-life sectors are used with reducing premium to get insurance deals This method is only suitable for corporate customers, where customer relationship and product prices play decisive role in winning the deal However, or individuals, price is not all Instead of price, product benefits and services are more important Because they are the person, who directly using insurance, therefore product and service qualities are their main interests As the result, to be successful on this market, local insurers will need to concentrate more on improving their product and service quality to meet customer’ requirements Particularly, local insurers should: Firstly, make the insurance policy more transparent and friendly to customers so that they can easily and fully understand their benefits and liability to get claim payment where eligible Secondly, streamline the operational process to save time and efforts of customers For example: local insurers can reduce the time of claim handling by applying technology, simplify claim documents and improving labor productivity 76 CONCLUSION Similar to neighbor Asean countries, Vietnam’s non-life insurance market is dominated by local insurers while the life insurance market is by foreign insurers In particular, on non-life insurer market, there are only companies with 100% foreign invested capital companies among 30 companies By contrast, this number is 11 foreign insurers out of 16 insurers in total Main life products are the traditional endowment insurance and recently, investment insurance is also developed significantly due to the improvement in income of Vietnamese people In term of non-life insurance, vehicle insurance and health insurance, which covers for basic needs, also accounts for the biggest shares of total premium However, nonlife insurers are facing high loss ratio of those two products In general, Vietnam’s insurance industry has seen impressively growth in recent years However, there are also potential signs of an unsustainable growth, e.g.: the frequency of insurance fraud is high, reducing premium recklessly is common practices especially among local non-life insurers, implication of information technology in business operation is still little etc By contrast, foreign insurers usually have great advantage of risk controlling, technology application, etc Therefore, local insurers would be very vulnerable in case that more foreign insurer participates into Vietnam market In terms of insurance legal framework, currently Vietnam had a quite open fair regulations for foreign insurers The reason is that Vietnam had completed its regulations since 2007 to meet its obligations in WTO Particularly, local and foreign insurers are treated quite to equally Foreign insurers are allowed to provide insurance in Vietnam under different legal entities, i.e.: 100% foreign-invested capital companies, company with local partners, branches (except for life insurance branches) Some additional requirements for foreign insurance companies to open business in Vietnam are the only exceptional discriminations Regarding crossborder trade in insurance, Vietnam also limits to just several products, e.g.: marine and aviation insurance etc 77 In comparison with Vietnam’s commitments in TPP, in general there is no major difference In particular, with TPP, Vietnam allows foreign insurance companies from other TPP’s member to provide marine insurance, aviation insurance, insurance for goods in international transit; reinsurance and retrocession; brokerage services, and other services auxiliary to insurance (such as: consultancy, actuarial, risk assessment and claim settlement services) to foreign and local companies/or citizens within Vietnam’s territory Therefore, there are differences compared with current regulations, which are: firstly, foreign insurers can provide those insurance not only to foreigners in Vietnam but also to Vietnamese people; secondly, they can sell those insurance directly to consumers without brokers For other insurance products, foreign insurers can theoretically provide via cross-border trade through a local broker Yet Vietnam may apply some restriction measures to the purchase by persons located in Viet Nam Besides the cross border trade, there are other insurance commitments of Vietnam in TPP, e.g.: board of director, market access, postal insurance entities etc However, in general, they not have big impact to Vietnam current legal framework because of two reason as follows: firstly, Vietnam’s current regulations have already meet those requirements; secondly, TPP has an exceptional mechanism for member country to protect some part of their laws and Vietnam has utilized this mechanism to reserve some TPP requirements that Vietnam does not meet yet For example: Vietnam reserves the right to apply some different requirements for the establishment of foreign companies in Vietnam, which of course goes against National Treatment commitment in TPP In short, Vietnam’s insurance commitments in TPP should not be worried by local insurers and authorities since there is no big difference to current law However, other commitments of Vietnam, which eliminate tariff and non-tariff measures to facilitate trade with TPP Members, leading to higher participation of foreign insurers into Vietnam insurance market will be the real threat to Vietnam 78 life and non-life insurance industry Particularly, for life insurance market, which is currently dominated by foreign insurers, the situation will be worsen once more foreign insurers decides to open businesses in Vietnam For non-life insurance market, where local insurers are taking lead, the competition will be much more intense Especially when local non-life insurers are still face lots of difficulties, including: low technologies, lack of skilled labor and long-term sustainable strategies etc Therefore, local insurers will have to take much efforts to innovate themselves and enhance the competitiveness Besides challenges, TPP also brings great opportunities for Vietnam to develop insurance industry Particularly, TPP will help to increase the demand of insurance for transported goods and automobile Demand of property insurance to protect manufactures and buildings will also rise since more foreign companies will invest in Vietnam, i.e.: in agriculture, apparel and textile manufacturing Demand of liability insurance, e.g.: public liability insurance, environmental liability insurance etc will be also higher because protecting business from unexpected losses during business operation is common practice of foreign companies Finally, trade will help to improve income of Vietnam, helping the local to afford life insurance, health and accident insurance Therefore, demand of those insurance will also increase However, such opportunity will be shared for both local insurance companies and foreign companies in Vietnam Since foreign insurers have great advantages in terms of capital, experience, technology and management, local insurers will have to take much efforts to innovate products, improve service quality and streamline operating process in order to compete with foreign insurance companies In front of above challenges and opportunities, preparation of local authority and insurers is still very little From the authority side, after the singing of TPP in early 2016, some conference to discuss TPP impacts and review laws have been taken places But since the gap between TPP commitments and current legal framework is small, the insurance law revision for TPP would be minimized Except for those conference, there is no other activities From the side of local 79 insures, there is also no special preparation for the TPP implementation The reason is the TPP insurance commitments is considered an “old” issue to local authority and insures They have practiced with the competition from foreign insures long before the appearance of TPP, i.e.: back from 2007 The TPP may only push the competition level to a higher level In fact, both local insurers have taken lots of efforts to their enhance competitiveness since WTO accession, e.g.: improve the customer service quality, invest in technology application etc Local authority also have carried many activities in order to promote the growth of insurance market, e.g.: controls to prevent insurance fraud, ensure compliance of insurers to local regulation… However, the author’s opinion is that above efforts are still not enough and local insurers may have to pay for poor preparation The reason is that though lots of innovation had been made by local insurers in recent year, there are still many limitations existed For example: the unfair competition by reducing premium recklessly is still very common and even though local authority, i.e.: MOF had risen its voice, the problem still not be fixed Another example is that there is lack of skilled actuaries to participate in product development, especially among local nonlife insurance Therefore, there is no big difference in product design of those insurers Some insurers even copycats all product (from insurance benefits to premium) of its rival insurers Besides the TPP, Vietnam is likely to sign another new FTAs Sooner or later Vietnam will have to face more intense competition from foreign insurers Therefore, Vietnam authority and insurers needs to take a more serious look at theirs situation and to carefully prepare for the implementation of not only TPP but also any future FTAs 80 REFERENCE ACE, TRANS-PACIFIC OPPORTUNITIES, at 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OPPORTUNITIES FOR VIETNAM’S INSURANCE INDUSTRY AFTER EFFECTIVENESS OF TPP .40 3.1 Challenges for Vietnam’s insurance industry 40 a Challenges for life insurance industry .40 b Challenges for. .. overview and Vietnam’s insurance commitments in TPP Chapter 3: Challenges and Opportunities for Vietnam’s insurance industry after effectiveness of TPP Chapter 4: Vietnam’s preparation for TPP and. .. non-life insurance industry .44 3.2 Opportunities for Vietnam’s insurance industry 52 a Opportunities for life insurance industry 52 b Opportunities for non-life insurance industry