Consumer Duty and fair value
Delivering and evidencing good outcomes across products and services, price and value, consumer understanding and consumer support, including for vulnerable customers.
Insurance brokers & intermediaries
How do insurance intermediaries evidence good advice, strong oversight and fair outcomes?
Seven years as Head of Group Compliance for an insurance and mortgage intermediary group, overseeing 160 self-employed advisers, and later consultancy for regulated insurance firms. Practical support for brokers and intermediaries who want their advice process, people and governance to stand up to scrutiny.
- 7 yearsleading group compliance for an insurance intermediary group
- 160 advisersrecruited, trained, supervised and file-checked
- SM&CRframeworks designed and implemented
- Deputy MLROand FCA permissions and regulatory relationships
Regulatory pressures
What insurance intermediaries are dealing with now
The FCA expects intermediaries to show that customers are sold the right cover, at fair value, by competent people, under clear accountability.
Quality of the sales and advice process
Demands and needs, advised and non-advised sales, disclosures, IPIDs and renewals all have to be done properly, every time, and be evidenced on file.
Accountability under SM&CR
Clear senior manager responsibilities, a working certification process and Conduct Rules that people understand and follow.
Competent, supervised advisers
Advisers who are qualified, assessed as competent, keeping up their CPD and supervised in a way that matches the risk of what they do.
Oversight of networks and third parties
Where advice or distribution runs through appointed representatives, self-employed advisers or partners, the principal remains responsible, and needs oversight to prove it.
Product governance as a distributor
Understanding the target market, getting the information you need from insurers, and making sure distribution arrangements deliver fair value to customers.
What I can do
Compliance support for brokers and intermediaries
Oversight of the insurance advice process
Advice and sales file checks, listening to calls, demands-and-needs and suitability reviews, disclosure checks, and clear feedback to advisers, with findings reported to management and tracked to improvement.
Adviser management and training and competence
Recruitment and onboarding checks, induction training, competence assessment and sign-off, ongoing supervision and CPD, and a training and competence framework that meets the TC sourcebook, whether advisers are employed or self-employed.
SM&CR design and implementation
Responsibilities maps, statements of responsibilities, prescribed responsibilities, certification and annual fitness and propriety assessments, and Conduct Rules training, built to fit how your firm actually runs.
Compliance and conduct risk frameworks
Group compliance frameworks, policies and procedures, compliance monitoring, conduct risk management and governance reporting, including across group companies.
Appointed representative and network oversight
Onboarding and ongoing oversight of appointed representatives and self-employed advisers, periodic reviews and management information, so the principal can evidence control.
Consumer Duty and distributor product governance
Consumer Duty implementation and outcome monitoring for intermediaries, fair value input from a distributor's perspective, and making sure products reach the right target market.
Insurer and supplier oversight
Monitoring insurer and supplier programmes, due diligence and annual periodic reviews of the providers your business relies on.
FCA permissions, submissions and financial crime
Managing FCA permissions and regulatory submissions, preparing for audits, and proportionate AML and KYC controls for intermediaries.
The rulebook
The FCA Handbook modules I work with
The core rules for general insurance intermediaries and brokers, and what support looks like under each.
ICOBS
Insurance: Conduct of Business. Customer classification, status and remuneration disclosure, demands and needs, advised and non-advised sales, IPIDs and renewals. I review processes, scripts and files against it.
SYSC and COCON
Systems and controls, SM&CR and Conduct Rules. Senior Management Functions, prescribed responsibilities, certification functions, Conduct Rules, outsourcing and internal controls.
PRIN and PRIN 2A
Principles for Businesses and the Consumer Duty. Principle 12 and the four outcomes: products and services, price and value, consumer understanding and consumer support.
PROD 4
Product governance for insurance. Distributor responsibilities, target market and fair value, and the information flow between intermediary and insurer.
TC
Training and Competence. Competence standards, assessment, supervision, CPD and qualification expectations for people who advise on or arrange insurance.
PERG 5
Perimeter guidance on insurance distribution. Which activities are regulated (arranging, advising, assisting in administration) and what that means for your permissions.
Typical engagements
Where firms usually start
01
Advice file review
An independent sample review of sales and advice files and calls, with rated findings, adviser feedback and a practical improvement plan.
02
SM&CR and T&C health check
A review of responsibilities, certification, fitness and propriety, and your training and competence arrangements, with the documents brought up to date.
03
Ongoing compliance support
A set number of days each month covering monitoring, file checks, adviser supervision support, board reporting and regulatory updates.
Running an insurance intermediary or broker?
Tell me about your firm and your advisers, and I'll suggest a sensible first step.