Insurance Guide
The rules and guidelines on Insurance Regulation can be found in the Insurance Conduct
of Business sourcebook. Below we have detailed some of the key points regarding
insurance regulation.
Extent of The Regulation
What is covered by the insurance regulations?
The insurance regulations are applicable to anybody who is involved in the sale and
administration of general insurance and pure protection contracts.
Can I have some examples of what 'general insurance' and 'pure protection' mean?
A general insurance contract would include plans such as motor insurance, buildings
and contents insurance and ASU cover. Pure protection would encompass plans such
as income protection insurance and term cover.
Are there any 'insurance' contracts that are not covered by the regulation?
There are a few that are not covered. For example, re-insurance contracts do not
fall under the scope of regulation. In addition Long Term Care plans are regulated
but not under the insurance rules; instead they are regulated under the FSA’s investment
business rules.
Documentation Requirements
How do I have to evidence the suitability of my advice?
The FSA rules state that for all sales a 'Demands and Needs Statement' must be provided
to the customer. This statement needs to outline the customer’s personal circumstances
and explain how a recommendation meets the needs of the customer.
Do I need to produce 'Demands and Needs Statements' for commercial clients?
Although insurers can in certain circumstances not provide statements to commercial
clients, this is not an option for intermediaries.
Therefore a ‘Demands and Needs
Statement’ must be produced for all personal and commercial customers.
Are there any template 'Demands and Needs Statements' that I can use?
No. The FSA have provided some example statements but have not provided any templates.
The reason for this is that they believe each customer will have unique personal
circumstances and therefore by definition each statement will need to be tailored
for those unique circumstances.
Do I need to provide an IDD the same as I do for mortgages?
As soon as you make contact with a client you will need to provide them with an Initial
Disclosure Document (IDD). This is a document that describes some basic details
of the firm and its relationship with a client. There are prescribed pieces of information
that must be included in the document, such as your firm's name and status, the
services that it offers and the cost of these services.
If you are conducting both Mortgage and Insurance business with a client then you can use a
Combined Initial Disclosure Document (CIDD),
although this is not compulsory.
Information to customers
Do I have to disclose the commission that I receive to my clients?
There is no requirement to disclose commission that you have received to either
retail or commercial clients. However, if the client requests this information then
you are obliged to provide it.
Does my client have a right to cancel their policy?
Anybody who takes out a general insurance contract will have 14 days in which they
can cancel it. For pure protection contracts the period is slightly longer at 30
days.
If I am recommending a group policy to a commercial client do I still need to provide
information to all employees?
Not directly. You will need to provide the relevant documentation to the employer
and advise them to provide a copy of the policy summary to the employees and also
make them aware that a copy of the policy document is available on request.
Further information
Where can I look if I want more information?
The detailed rules can be found in the Insurance Conduct of Business (ICOB) sourcebook.
This can be viewed by following this link.
Below is a table of contents for ICOB that you may find helpful.
ICOB 1 Application and Purpose
ICOB 2 General Rules
ICOB 3 Financial Promotion
ICOB 4 Advising and Selling Standards
ICOB 5 Product Disclosure
ICOB 6 Cancellation
ICOB 7 Claims Handling
ICOB 8 Distance non-investment mediation contracts with retail customers