Since the FSA assumed responsibility for the regulation of general insurance mediation in January 2005 we have helped many firms with their compliance arrangements and we provide a range of ongoing support tailored to the very different needs of different types and sizes of intermediary. We have also carried out a number of larger-scale compliance reviews for firms in this sector.
We have particular experience of developing workable compliance arrangements for intermediaries who trade with customers via web-based channels and with large scale call centre providers.
In January 2009 regulation was extended further to the sale of travel insurance alongside a holiday or other related travel. With our experience of helping firms for whom regulated business is a secondary activity, we are well placed to help travel firms review their options and to assist with an application for authorisation where necessary.
The FSA have made great efforts to simplify their communications with smaller insurance firms and to make their regulatory life as simple as possible. But with the best will in the world the FSA's material has to be fairly generic, and many firms still need help in identifying what is most important for them, and in dealing with the six-monthly RMAR returns to the FSA and other occasional FSA enquiries. Our basic support service, which combines a tailored newsletter/reminder service with a modest amount of consultancy support to be called upon as required, is designed to fulfil this "hand-holding" need, and many smaller insurance clients use it for just this purpose.
Client money has been – and remains – a particular focus for the FSA in the insurance mediation area. They have put out much guidance material about this, and their supervisory approach in this area can has become harder-edged. We have helped a number of firms with client money procedures and reviews of their arrangements.
Payment Protection Insurance is another continuing FSA priority, with a number of high profile enforcement cases. The FSA have made it clear that they will continue their work in this area. Firms selling PPI – including secondary intermediaries for whom it represents only a very small part of their total business – need to ensure that their systems are robust and delivering the outcomes the FSA expect to see. We can help firms review their performance in this area and make improvements where necessary.
All firms that deal in any way with retail customers need to review how the principles of "Treating Customers Fairly" (TCF) are reflected in their business: FSA deadlines for implementing TCF into the business have now passed, and all firms must ensure that they can demonstrate that they treat customers fairly through the use of suitable management information. We can help insurance firms tackle this in a way that is appropriate and proportionate to their business.