August 2014 GENERAL INSURANCE. The Latest FCA Enforcement Action
|
|
- Marion Holt
- 5 years ago
- Views:
Transcription
1 August 2014 GENERAL INSURANCE The Latest FCA Enforcement Action
2 Introduction The Financial Conduct Authority's (FCA) enforcement action against Aegon subsidiary, Stonebridge International Insurance Limited 1, is the latest significant fine against firms selling insurance products, following on from Swinton Group (16 July 2013) and Card Protection Plan (CPP) (14 November 2012). As well as a financial penalty of 8,373,600, Stonebridge is to carry out a past business review and has already paid 400,000 in redress to UK customers. Stonebridge Stonebridge sold insurance products for personal accident, accidental death and accidental cash plans to low and middle income customers in the UK and EU. The sales process was outsourced to companies which contacted customers by telephone using telesales scripts provided by Stonebridge. Between April 2011 and December 2012, a total of 486,000 customers bought policies providing revenue in excess of 93 million. Stonebridge breached Principle 6 of the Principles for Businesses (a firm must pay due regard to the interests of its customers and treat them fairly) by: targeting low and middle income customers without higher education or professional qualifications with telesales scripts that did not give clear, fair and "balanced" information; using a sales process that emphasised concessionary introductory periods and the availability of cancellation rights to persuade customers to take out policies, suggesting that Stonebridge relied on its customers' inertia to sell policies; designing telesales scripts to "steer" customers with families towards more extensive and costly products which they did not necessarily need; and when customers wanted to cancel their policies, they were presented with barriers to cancellation. There were also serious weaknesses in Stonebridge's systems and controls including, crucially, its internal governance which should have alerted senior managers to inherent failings in the sales and marketing process. The information available to its management on sales data and trends was incomplete and unclear which negated the value of the "TCF dashboard" intended to monitor outcomes. Nor did its Board and various risk committees effectively oversee and challenge the identification and management of the risks to which its customers were exposed. The board committee with overarching oversight of the risk framework was found by the FCA to have provided "an inadequate level of sustained challenge of TCF risks." Swinton and CPP The Stonebridge fine follows the significant fines for high street broker, Swinton ( 7.38m), and card protection insurer, CPP ( 10.5m), where redress was also significant. Swinton did not consider customers' interests sufficiently when pursing an aggressive sales strategy of monthly add-on insurance products to counter a decline in sales elsewhere in its business. Again, it failed to provide adequate information or a sufficient explanation in sales scripts to customers about products and this fact was not identified (and acted upon) due to weaknesses in corporate governance, exemplified by not taking reasonable care to organise and control its compliance procedures. CPP provided customers with misleading information about cover which was either not required or where its sales force had exaggerated the risks concerned. In all three cases the firms had objection handling strategies. Insurance in the spotlight? With these fines, the FCA's general insurance add-ons market study, the thematic review on commercial brokers conflicts of interest, earlier thematics for mobile phone insurance and motor legal expenses insurance, and the Competition and Markets Authority's investigation into the private motor insurance market, the insurance sector might feel under the regulatory spotlight. Moreover, later this year the FCA will carry out thematic work in relation to cover holders, premium finance, commercial claims and client money as well as carry over work in relation to motor legal expenses insurance and mobile phone insurance. Discernible trends are making themselves apparent: not surprisingly, the FCA remains focussed on good customer outcomes. Stonebridge failed to treat customers fairly and to deliver on the FCA's TCF outcomes 2 ; 1 See 2 The six improved consumer outcomes which are the aims of the FSA/FCA's TCF initiative. These outcomes were first outlined
3 the importance of appropriate systems and controls and proper oversight. Specifically, there should be robust challenge as to whether existing systems and controls (see below) are fit for purpose; and whether customers are getting value for money? We see this as a question that will receive ever greater focus. In all of the above final notices it could be said that the cover was sold rather than bought and, while all were "low cost" products, there is an inherent question as to their value for customers. TCF Lessons When assessing outcomes, the FCA expects firms to put customers' interests at the heart of their sales process 3. In particular: the obligation to provide information to customers which is clear, fair and not misleading is particularly acute where the target market consists of vulnerable consumer groups. Moreover, firms need to ensure that customers receive balanced information; customers' best interests in terms of the appropriateness of a product must be embedded into its design, where factors such as the claims ratio 4 may be relevant as it can give an indication of the value of a product; and the sales process must not be distorted by aggressive sales targets or by subverting customer protections (e.g., using the availability of cancellation rights to persuade hesitant customers). Systems and controls The importance of taking reasonable care to organise and control a firm's affairs responsibly and effectively, with adequate risk management systems, must be emphasised, for example: firms must take reasonable steps to ensure that sales calls are properly monitored and subject to quality assurance; when firms use outsourcers adequate information must be obtained to enable the identification, measurement and identification of risks; and internal compliance and governance processes need to be robust and sufficiently resourced and independent of business to act on the information to safeguard TCF outcomes for customers. Value for money On the question of value for money, it is worth remembering the FCA has said in relation to the add-ons market study that: "[The study] confirmed that selling a product as an add-on often lead to consumers purchasing products that were of poor value and not what they needed. We also found that the value of general insurance products is not always clear. We remain committed to strengthening the transparency and comparability of the value of general insurance products and have proposed to impose a requirement on firms to publish claims ratios as a measure of the value of a product." 5 in the FSA's July 2006 publication, Treating customers fairly towards fair outcomes for consumers and remain core to what the FCA expects of firms. 3 The requirement to implement these outcomes is firmly rooted in the FCA s Principles for Businesses. 4 The difference in percentage terms between the amount paid out and what is received in premiums. 5 FCA Press Release, General Insurance Ad ons Market Study, 24 July
4 For further information please contact: Robert Garwood Managing Associate Paul Harris Associate Jennifer Young Associate
5 addleshawgoddard.com Doha, Dubai, Hong Kong, Leeds, London, Manchester, Muscat, Singapore and Tokyo* *a formal alliance with Hashidate Law Office 2017 Addleshaw Goddard LLP. All rights reserved. Extracts may be copied with prior permission and provided their source is acknowledged. This document is for general information only. It is not legal advice and should not be acted or relied on as being so, accordingly Addleshaw Goddard disclaims any responsibility. It does not create a solicitor-client relationship between Addleshaw Goddard and any other person. Legal advice should be taken before applying any information in this document to any facts and circumstances. Addleshaw Goddard is an international legal practice carried on by Addleshaw Goddard LLP (a limited liability partnership registered in England & Wales and authorised and regulated by the Solicitors Regulation Authority) and its affiliated undertakings. Addleshaw Goddard operates in the Dubai International Financial Centre through Addleshaw Goddard (Middle East) LLP (registered with and regulated by the DFSA), in the Qatar Financial Centre through Addleshaw Goddard (GCC) LLP (licensed by the QFCA), in Oman through Addleshaw Goddard (Middle East) LLP in association with Nasser Al Habsi & Saif Al Mamari Law Firm (licensed by the Oman Ministry of Justice) and in Hong Kong through Addleshaw Goddard (Hong Kong) LLP (a limited liability partnership registered in England & Wales and registered and regulated as a foreign law firm by the Law Society of Hong Kong, operating in Hong Kong as a Hong Kong limited liability partnership pursuant to the Legal Practitioners Ordinance) in association with Francis & Co. In Tokyo, legal services are offered through Addleshaw Goddard's formal alliance with Hashidate Law Office. A list of members/principals for each firm will be provided upon request. The term partner refers to any individual who is a member of any Addleshaw Goddard entity or association or an employee or consultant with equivalent standing and qualifications. If you prefer not to receive promotional material from us, please us at unsubscribe@addleshawgoddard.com. For further information please consult our website or
INSURANCE MEDIATION DIRECTIVE II
August 2012 INSURANCE MEDIATION DIRECTIVE II Major changes ahead Background The Insurance Mediation Directive I ("IMD I"), which had to be implemented by all EU Members States in 2005, regulates the point
More informationTHE IDD COMES INTO FORCE
February 2016 THE IDD COMES INTO FORCE Insurance THE INSURANCE DISTRIBUTION DIRECTIVE After a long reform process initiated in 2009, the final text of the Insurance Distribution Directive (IDD) was finally
More informationPROBATE. Pricing Information
PROBATE Pricing Information This document sets out the pricing guidance for probate matters where: There is a valid, uncontested Will; and All of the estate assets are within England & Wales. Applying
More informationBREXIT AND DATA PROTECTION Q & A
BREXIT AND DATA PROTECTION Q & A What happens now? The UK decision to leave the EU will not affect existing data protection and privacy laws in the UK. These laws (the UK Data Protection Act 1998 (DPA)
More informationOctober 2012 JOURNEY TO THE FCA. What should we expect?
October 2012 JOURNEY TO THE FCA What should we expect? Introduction On 15 October 2012 the Financial Services Authority (FSA) published a document entitled 'Journey to the FCA' (the document). In the foreword
More informationEMPLOYMENT TRIBUNAL. Pricing Information
EMPLOYMENT TRIBUNAL Pricing Information This document sets out the pricing guidance for employment matters where: a business wishes to defend a claim for unfair or wrongful dismissal in the Employment
More informationFSA RETAIL CONDUCT RISK OUTLOOK
March 2011 FSA RETAIL CONDUCT RISK OUTLOOK Client Briefing FSA s Retail Conduct Risk Outlook 2011 key points The FSA published its Retail Conduct Risk Outlook (RCRO) for 2011 on 28 February. In previous
More informationSENIOR MANAGERS AND CERTIFICATION REGIME
SENIOR MANAGERS AND CERTIFICATION REGIME Summary of PS 18/14 Extending the Senior Managers & Certification Regime to FCA firms - Feedback to CP17/25 and CP17/40, and near-final rules Published on 4 July
More informationACQUIRING A UK PUBLIC COMPANY
ACQUIRING A UK PUBLIC COMPANY Introduction With few governmental restrictions on foreign ownership, takeovers of UK listed companies by international bidders are comparatively common. Indeed, the regulatory
More informationSUMMARY OF THE PROPOSALS FROM THE FCA IN ITS HIGH COST CREDIT REVIEW
SUMMARY OF THE PROPOSALS FROM THE FCA IN ITS HIGH COST CREDIT REVIEW Consultation Paper High Cost Credit Review Consultation on rent-to-own, home collected credit, catalogue credit and store cards, and
More informationCORPORATE CRIME AND INVESTIGATIONS
CORPORATE CRIME AND INVESTIGATIONS Famed for handling complex financial crime matters on behalf of large corporations and individuals. Particularly experienced in cases that involve market manipulation,
More informationASSET MANAGEMENT COSTS AND CHARGES
April 2017 ASSET MANAGEMENT COSTS AND CHARGES Are the FCA and the EU singing from the same hymn sheet? Asset managers will be hit by a wave of new regulation when MiFID II applies from 3 January 2018,
More informationFUNDS AND INDIRECT REAL ESTATE
FUNDS AND INDIRECT REAL ESTATE INTRODUCTION They offer proactive client support and take a commercial and pragmatic approach. They re efficient in their execution of transactions. A well-balanced firm
More informationNovember 2016 INVEST
November 2016 INVEST InVest November 2016 This month's roundup of developments affecting banks, wealth managers, brokers and funds sees a report from the European Commission on CRA regulation, the PRA
More informationADDLESHAW GODDARD. Finance Litigation and Investigations
2017 ADDLESHAW GODDARD Finance Litigation and Investigations They are very capable and on top of things, with a team that is good to work with. They have a good relationship with their clients, and are
More informationASSET FINANCE & LEASING. Delivering expert solutions
ASSET FINANCE & LEASING Delivering expert solutions Delivering expert solutions Winners of the Legal Firm of the Year award LEASING WORLD AWARDS 2014 A MEETING OF MINDS Asset finance is an increasingly
More informationADVISING POLICYHOLDERS
ADVISING POLICYHOLDERS We are the specialist insurance practice of Addleshaw Goddard LLP, a full-service international law firm with 232 partners and over 900 other legal staff and 11 offices in the UK
More informationREPUTATION & INFORMATION PROTECTION. The legal perspective
REPUTATION & INFORMATION PROTECTION The legal perspective Their advice was business focussed and useful in a business context. RECOGNISED SPECIALIST EXPERTISE CHAMBERS, 2018 The overall level of service
More informationPRODUCT LITIGATION, SAFETY AND RECALL
PRODUCT LITIGATION, SAFETY AND RECALL NAVIGATING THE COMPLEX ARENA OF PRODUCTS In a global market where technology is ahead of regulation, where consumer expectation and the demands of regulators to keep
More informationJune 2016 Q CORPORATE BORROWER UPDATE
June 2016 Q2 2016 CORPORATE BORROWER UPDATE 1 INTRODUCTION Welcome to the Q2 2016 edition of the Addleshaw Goddard Corporate Borrower Update. As we approach the halfway point in the calendar year (where
More informationCENTRAL ASIA BUSINESS GROUP
CENTRAL ASIA BUSINESS GROUP Addleshaw Goddard's lawyers have handled complex matters across numerous sectors and practice areas in the key jurisdictions across Central Asia. We have advised investors and
More informationNovember 2018 Q4 CORPORATE BORROWER UPDATE
November 2018 Q4 CORPORATE BORROWER UPDATE INTRODUCTION Welcome to the November 2018 edition of the Addleshaw Goddard Corporate Borrower Update. It's been a busy summer for our corporate banking team,
More informationBLOCKCHAIN: THE EVOLUTION
BLOCKCHAIN: THE EVOLUTION PART 1 - THE BASICS INTRODUCTION The aim of this article is to outline the development of blockchain the cryptographically secure method of recording and validating information
More informationEMPLOYMENT, INCENTIVES AND IMMIGRATION HORIZON SCANNER 1 JANUARY 2019 ONWARDS
EMPLOYMENT, INCENTIVES AND IMMIGRATION HORIZON SCANNER 1 JANUARY 2019 ONWARDS FUTURE KEY LEGISLATIVE DEVELOPMENTS 1. Companies (Miscellaneous Reporting) Regulations 2018. New company reporting requirements
More informationFINAL NOTICE Swinton confirmed on 9 October 2009 that it will not be referring the matter to the Financial Services and Markets Tribunal.
Financial Services Authority FINAL NOTICE To: Swinton Group Limited Of: 6 Great Marlborough Street Manchester Lancashire M1 5SW Date: 28 October 2009 TAKE NOTICE: The Financial Services Authority of 25
More informationFINAL NOTICE Capital One confirmed on 31 January 2007 that it will not be referring the matter to the Financial Services and Markets Tribunal.
Financial Services Authority FINAL NOTICE To: Capital One Bank (Europe) Plc Of: 350 Euston Road London NW1 3JJ Date: 15 February 2007 TAKE NOTICE: The Financial Services Authority of 25 The North Colonnade,
More informationTrust and confidence in the charities and not-for-profit sector. Trust and confidence in the charities and not-for-profit sector 1
Trust and confidence in the charities and not-for-profit sector Trust and confidence in the charities and not-for-profit sector 1 Contents Introduction 1 Charity governance 3 Executive pay and trustee
More informationFinancial Services Authority FINAL NOTICE. Egg Banking plc Citigroup Centre Canada Square London E14 5LB Date: 9 December 2008
Financial Services Authority FINAL NOTICE To: Of: Egg Banking plc Citigroup Centre Canada Square London E14 5LB Date: 9 December 2008 TAKE NOTICE: The Financial Services Authority of 25 The North Colonnade,
More informationGeneral insurance pricing conduct: getting the price right
General insurance pricing conduct: getting the price right Minds made for shaping financial services July 2018 When the financial services industry works well, it creates growth, prosperity and peace of
More informationTHE TRANSFORMATION OF INVESTMENT ADVICE: DIGITAL ADVISERS AS FIDUCIARIES
THE TRANSFORMATION OF INVESTMENT ADVICE: DIGITAL ADVISERS AS FIDUCIARIES Jennifer L. Klass and Eric L. Perelman Wharton Pension Research Counsel 2018 Symposium: The Disruptive Impact of FinTech on Retirement
More informationMONTHLY REGULATORY UPDATE JANUARY 2017
MONTHLY REGULATORY UPDATE JANUARY 2017 6 February 2017 The following is a summary of the pronouncements issued since our last regulatory update for the financial services sector issued on 3 January 2017.
More informationFinancial Services Authority
Financial Services Authority FINAL NOTICE To: Of: Sett Valley Insurance Services 18 Market Street New Mills High Peak Derbyshire SK22 4AE Date: 27 January 2010 TAKE NOTICE: The Financial Services Authority
More informationConsultation response
Consultation response SRA: Regulation of consumer credit activities Overview 1. Regulation of consumer credit activities is specialised and complex. Credit activities (and in particular debt collection)
More informationThe new UK Bribery Act: why you need to be prepared
April 2011 The new UK Bribery Act: why you need to be prepared The UK government's new Bribery Act of 2010 will come into force on 1 July 2011 (the "Bribery Act"), and the Government on 30 March provided
More informationFinancial Services Authority FINAL NOTICE. Redcats (Brands) Limited. 18 Canal Road Bradford West Yorkshire BD99 4XB. Date: 20 December 2006
Financial Services Authority FINAL NOTICE To: Redcats (Brands) Limited Of: 18 Canal Road Bradford West Yorkshire BD99 4XB Date: 20 December 2006 TAKE NOTICE: The Financial Services Authority of 25 The
More informationPinsent Masons in Spain
Pinsent Masons in Spain Pinsent Masons in Spain Pinsent Masons is a sector focussed global law firm. Our strategy is to invest in geographies that connect our clients to where they want to do business.
More informationSee article 36A4 of The Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, S.I. 2001/544. 2
SERVICE-SPECIFIC GUIDANCE NOTE Consumer Credit Who should read this? As at October 2014, the Phone-paid Services Authority notes that the primary providers of consumer credit services in the premium rate
More informationAnti-money laundering Annual report 2017/18
Anti-money laundering Annual report 2017/18 Anti-money laundering Contents 1 Introduction 4 2 Policy developments 5 3 OPBAS 7 4 How our AML supervision is evolving 8 5 Findings and outcomes 9 6 Financial
More informationFrom cradle to grave - EIOPA s dynamic approach to restoring consumer confidence in the sale of general insurance products.
SPEECH Manuela Zweimueller Director of Regulations From cradle to grave - EIOPA s dynamic approach to restoring consumer confidence in the sale of general insurance products. FCA General Insurance Sector
More informationFinancial Services Authority FINAL NOTICE. Liverpool Victoria Banking Services Limited County Gates Bournemouth Dorset BH1 2NF. Date: 29 July 2008
Financial Services Authority FINAL NOTICE To: Of: Liverpool Victoria Banking Services Limited County Gates Bournemouth Dorset BH1 2NF Date: 29 July 2008 TAKE NOTICE: The Financial Services Authority of
More informationRelevance of Operational Risk to the FCA Jill Savager Manager, Operational Risk, Financial Conduct Authority
Relevance of Operational Risk to the FCA Jill Savager Manager, Operational Risk, Financial Conduct Authority IOR Scottish Chapter Annual Conference Glasgow Caledonian University 01/11/13 1 What we will
More informationFINAL NOTICE. 1. For the reasons given in this Final Notice the Authority hereby imposes on Swinton a financial penalty of 7,380,400.
FINAL NOTICE To: Swinton Group Limited FRN: 309599 Address: 6 Great Marlborough Street Manchester M1 5SW Date: 16 July 2013 ACTION 1. For the reasons given in this Final Notice the Authority hereby imposes
More informationPinsent Masons in Qatar
Pinsent Masons in Qatar For over a decade, we have been serving both Qatari clients and their businesses and the wider local business community. We operate from our office in the iconic Tornado Tower in
More informationThe AML Challenge. Arab Bankers Association 2 December 2014
The AML Challenge Arab Bankers Association 2 December 2014 The key components of an AML programme Governance Senior Management AML Risk Assessment Systems and Controls Outsourcing and Reliance Assurance
More informationFINAL NOTICE. Sonali Bank (UK) Ltd, Osborn Street, London E1 6TD. (1) imposes on Steven Smith a financial penalty of 17,900; and
FINAL NOTICE To: Steven George Smith Reference Number: SGS01046 Address: Sonali Bank (UK) Ltd, 29-33 Osborn Street, London E1 6TD Date: 12 October 2016 1. ACTION 1.1 For the reasons given in this notice,
More informationFinancial Services Authority
Financial Services Authority FINAL NOTICE To: FSA Reference Number: Address: Date: Coutts & Company 122287 440 Strand, London WC2R 0QS 7 November 2011 1. ACTION 1.1 For the reasons given in this Notice,
More informationFINAL NOTICE RELEVANT STATUTORY PROVISIONS AND REGULATORY RULES/ PRINCIPLES
Financial Services Authority FINAL NOTICE To: Of: Hoodless Brennan Plc 40 Marsh Wall, London E14 9TP Date: 9 August 2006 TAKE NOTICE: The Financial Services Authority of 25, The North Colonnade, Canary
More informationProduct Governance and Funds. What is changing on the way to MiFID2. Mahrie Webb, Partner. Romeo Battigaglia, Partner. Caroline Hunter-Yeats, Partner
Product Governance and Funds What is changing on the way to MiFID2 Mahrie Webb, Partner Romeo Battigaglia, Partner Caroline Hunter-Yeats, Partner October 2015 Agenda Summary of the key Product Governance
More informationFinancial Services Authority. With-profits regime review report
Financial Services Authority With-profits regime review report June 2010 Contents 1 Overview 3 2 Our approach 9 3 Governance 11 4 Consumer communications 17 5 With-profits fund operations 23 6 Closed
More informationFinancial Services Authority FINAL NOTICE. DB UK Bank Limited (trading as DB Mortgages) Winchester House 1 Great Winchester Street London EC2N 2DB
Financial Services Authority FINAL NOTICE To: DB UK Bank Limited (trading as DB Mortgages) Of: Winchester House 1 Great Winchester Street London EC2N 2DB Date: 15 December 2010 TAKE NOTICE: The Financial
More informationWHO WILL DECIDE FOR YOU WHEN YOU CAN T?
WHO WILL DECIDE FOR YOU WHEN YOU CAN T? Don t leave your life in the hands of a stranger Glossary of terms Assets any item of value owned by an individual or corporation Attorney a person appointed to
More informationWhat to do in the first hour of a Competition Dawn Raid Checklist & Guidelines
What to do in the first hour of a Competition Dawn Raid Checklist & Guidelines Checklist Action Point The Officials arrive They introduce themselves and ask to see either a particular person or the most
More informationFINAL NOTICE. Sesame Limited. Authority Reference Number: Holly Bank Road Huddersfield HD3 3HN. Date: 5 June 2013 ACTION
FINAL NOTICE To: Sesame Limited Authority Reference Number: 150427 Address: Independence House Holly Bank Road Huddersfield HD3 3HN Date: 5 June 2013 ACTION 1. For the reasons given in this notice, the
More informationFINAL NOTICE. To: Redstone Mortgages Limited Of: 2 Royal Exchange Buildings, London EC3V 3LF Date: 12 July 2010
Financial Services Authority FINAL NOTICE To: Redstone Mortgages Limited Of: 2 Royal Exchange Buildings, London EC3V 3LF Date: 12 July 2010 TAKE NOTICE: The Financial Services Authority of 25 The North
More informationPillar 3 Regulatory Disclosure (UK)
Pillar 3 Regulatory Disclosure (UK) As at 30 June 2017 Approved by the Board 12 December 2017 THE UK CAPITAL CONSOLIDATION REGULATED GROUP, INCLUDING: PRAEMIUM ADMINISTRATION LTD (FRN 463566) SMART INVESTMENT
More informationGovernance under AIFMD
www.pwc.co.uk Governance under September 2011 Governance under The Alternative Investment Fund Managers Directive () subjects managers of alternative investment funds (AIFs) to compulsory regulation in
More informationStatement of Insolvency Practice 6 England and Wales
Statement of Insolvency Practice 6 England and Wales DEEMED CONSENT AND DECISION PROCEDURES IN INSOLVENCY PROCEEDINGS INTRODUCTION 1. Insolvency practitioners play a key role in ensuring that persons entitled
More informationThe FSA s role under the Electronic Money Regulations 2011
Financial Services Authority The FSA s role under the Electronic Money Regulations 2011 Our approach March 2011 Preface The second Electronic Money Directive (2EMD) will be implemented in the UK on 30
More informationMiddle East Regulatory Update
Middle East Regulatory Update Muneer Khan Partner - Dubai Ahmed Butt Partner - Riyadh Ali Hassan Senior Representative Europe & North America DIFC Authority 7 & 8 October 2015 Agenda Introduction Saudi
More informationFSA DISCIPLINARY NOTICE
FSA DISCIPLINARY NOTICE FSA has given a Final Notice to Royal & Sun Alliance Life & Pensions Limited, Royal & Sun Alliance Linked Insurances Limited and Sun Alliance and London Assurance Company Limited
More informationBERMUDA MONETARY AUTHORITY THE INSURANCE CODE OF CONDUCT FEBRUARY 2010
Table of Contents 0. Introduction..2 1. Preliminary...3 2. Proportionality principle...3 3. Corporate governance...4 4. Risk management..9 5. Governance mechanism..17 6. Outsourcing...21 7. Market discipline
More informationPrincipals and their appointed representatives in the general insurance sector
Financial Conduct Authority Thematic Review TR16/6 Principals and their appointed representatives in the general insurance sector July 2016 Principals and their appointed representatives in the general
More informationAnti-Bribery Policy. 1. Introduction and purpose
Anti-Bribery Policy 1. Introduction and purpose 8Safe UK Limited ("8Safe UK" or the Company ) is committed to adhering to the highest standards of business conduct; compliance with the law and regulatory
More informationHome Office consultation: Improving police integrity: reforming the police complaints and disciplinary system
Home Office consultation: Improving police integrity: reforming the police complaints and disciplinary system The Police Foundation s response The Police Foundation is the only independent charity focused
More informationFINAL NOTICE For the reasons given in this notice, the Authority hereby imposes on W H Ireland Limited ("WHI"):
FINAL NOTICE To: W H Ireland Limited Firm Reference Number: 140773 Date: 22 February 2016 1. ACTION 1.1. For the reasons given in this notice, the Authority hereby imposes on W H Ireland Limited ("WHI"):
More informationOpinion on monetary incentives and remuneration between providers of asset management services and insurance undertakings
EIOPA-BoS-17/295 11 December 2017 Opinion on monetary incentives and remuneration between providers of asset management services and insurance undertakings 1. Legal basis 1.1. The European Insurance and
More informationFINAL NOTICE. UNAT DIRECT Insurance Management Limited (UNAT)
Financial Services Authority FINAL NOTICE To: Of: UNAT DIRECT Insurance Management Limited (UNAT) 96 George Street Croydon Surrey CR9 1BU Date: 19 May 2008 TAKE NOTICE: The Financial Services Authority
More informationDear Assignment / News / Business Section Editor
Dear Assignment / News / Business Section Editor Hong Kong Institute of Certified Public Accountants takes disciplinary action against a certified public accountant (practising), a certified public accountant
More informationPRACTICE NOTE REPORTS ON INTERNAL CONTROLS OF INVESTMENT CUSTODIANS MADE AVAILABLE TO THIRD PARTIES
PRACTICE NOTE 860.2 REPORTS ON INTERNAL CONTROLS OF INVESTMENT CUSTODIANS MADE AVAILABLE TO THIRD PARTIES (Issued June 1999; revised September 2004 (name change); revised May 2010) PN 860.2 (May 2010)
More informationCapital Requirements Directive Pillar 3 Disclosures For the year ended 31 August 2017
Capital Requirements Directive Pillar 3 Disclosures For the year ended 31 August 2017 Contents INTRODUCTION... 2 RISK MANAGEMENT POLICIES AND OBJECTIVES... 3 BOARD & SUB-COMMITTEES... 3 THREE LINES OF
More informationFinancial Services and Markets
Financial Services and Markets Best execution FCA findings action required Executive Summary FCA Thematic Review On 31 July 2014, the Financial Conduct Authority ("FCA") published TR14/13 ("the Review"),
More informationFINAL NOTICE. Policy Administration Services Limited. Firm Reference Number:
FINAL NOTICE To: Policy Administration Services Limited Firm Reference Number: 307406 Address: Osprey House Ore Close Lymedale Business Park Newcastle-under-Lyme Staffordshire ST5 9QD Date: 1 July 2013
More informationLocal Government pensions a glance
22 June 2009 Local Government pensions reforms @ a glance is a free monthly publication from the Pinsent Masons Pensions Group. It is a quick reference guide giving you the latest position on the main
More informationFINAL NOTICE. Santander UK plc FRN: Triton Square, Regent s Place, London NW1 3AN. Date: 19 December ACTION
FINAL NOTICE To: Santander UK plc FRN: 106054 Address: 2 Triton Square, Regent s Place, London NW1 3AN Date: 19 December 2018 1. ACTION 1.1. For the reasons given in this Final Notice, the Financial Conduct
More informationFINAL NOTICE. Nomura House, 1 St Martin s-le-grand, London EC1A 4NP
Financial Services Authority FINAL NOTICE To: Of: Nomura International Plc ( Nomura ) Nomura House, 1 St Martin s-le-grand, London EC1A 4NP Dated: 16 November 2009 TAKE NOTICE: The Financial Services Authority
More informationV0215 Copyright Comply
An Introduction to Financial Conduct Authority (FCA) Regulation V0215 FCA Regulation Module Objectives Welcome to the training module for an introduction to the Financial Conduct Authority Regulation for
More informationGroup Financial Statements
Group Financial Statements Group Financial Statements 80 Statement of Directors Responsibilities 81 Independent Auditor s UK Report 87 Independent Auditor s US Report 88 Group Financial Statements 88 Group
More informationResponse to SRA Consultation on regulation of consumer credit activities
Response to SRA Consultation on regulation of consumer credit activities 15 December 2014 2014 The Law Society. All rights reserved. The Law Society s response to the SRA s consultation on regulation of
More informationDoing Business in the UAE September Alan Wood and Nigel Wilson Pinsent Masons LLP Dubai Branch
Doing Business in the UAE September 2009 Alan Wood and Nigel Wilson Pinsent Masons LLP Dubai Branch Introduction The Legal Framework of the UAE Legal Issues faced operating in the UAE Trading from Overseas
More informationThe accounts and audit rules applicable to Jersey companies
GUIDE The accounts and audit rules applicable to Jersey companies Last reviewed: January 2017 Contents Introduction 2 Requirement to prepare accounts 2 Entitlement to copies of accounts 2 Time limits for
More informationBIBA s response to HM Treasury consultation A new approach to regulation building a stronger system
4 April 2011 HM Treasury 1 Horse Guards Road London SW1A 2HQ Dear Sirs BIBA s response to HM Treasury consultation A new approach to regulation building a stronger system The British Insurance Brokers'
More informationLloyd s minimum standards
Lloyd s minimum standards Lloyd s minimum standards Ms11 Conduct Risk Ms12 - Operating at Lloyd s June 2014 July 2014 Disclaimer 1 Introduction The Franchise Board is concerned to protect the interests
More informationThe SCA approves Regulations concerning Securities Lending and Borrowing, Short Selling, Market Making and Liquidity Providers
Briefing note October 2012 The SCA approves Regulations concerning Securities Lending and Borrowing, Short Selling, Market Making and The UAE Securities and Commodities Authority (the "SCA") has issued
More information116 Statement of directors responsibilities. Independent auditor s reports 117 Group income statement 122 Group statement of comprehensive income 123
Financial statements 116 Statement of directors responsibilities 117 Consolidated financial statements of the BP group Independent auditor s reports 117 Group income statement 122 Group statement of comprehensive
More informationFinancial Services Authority FINAL NOTICE. Perspective Financial Management Limited FRN: Date: 24 January 2011
Financial Services Authority FINAL NOTICE To: Perspective Financial Management Limited FRN: 178690 Date: 24 January 2011 TAKE NOTICE: The Financial Services Authority of 25 The North Colonnade, Canary
More informationConnected globally, committed locally Financial institutions sector
Connected globally, committed locally Financial institutions operate against a backdrop of an ever changing regulatory landscape, global economic uncertainty and new market entrants. A co-ordinated global
More informationCapital Requirements Directive. Pillar 3 Disclosures
Capital Requirements Directive Pillar 3 Disclosures For the year ended 31 August 2016 INDEX Page INTRODUCTION 2 RISK MANAGEMENT POLICIES AND OBJECTIVES 3 CAPITAL ADEQUACY ASSESSMENT, CAPITAL RESOURCES
More informationMiFID2 for asset managers headlines and roadmaps
MiFID2 for asset managers headlines and roadmaps Nick Colston Darren Fox Wednesday 05 & Thursday 06 October 2016 Introduction what we ll cover today 1. Re-cap and recent developments 2. L2 Directive: finalised
More informationBrexit Paper 2: International Arbitration
1 Brexit Paper 2: International Arbitration Summary For decades, London has been the seat of choice for parties seeking to resolve international commercial disputes through arbitration. But the capital
More informationNew AML Regime for the DIFC
Briefing note October 2012 New AML Regime for the DIFC The Dubai Financial Services Authority ("DFSA") has released Consultation Paper No. 86 regarding proposed changes to the DFSA's Anti-Money Laundering
More informationAutumn Legal Update: Duties and Trade Errors
Autumn Legal Update: Duties and Trade Errors Robert Turner, Paul Baker, Gerard Heyes, Adam Blair and Mark Uttley 11 & 12 October 2017 Introduction Duties Considerations Fiduciary Definition, Policies and
More informationFINAL NOTICE. Unit 8a, Maple Estate, Stocks Lane, Barnsley, South Yorkshire S75 2BL
Financial Services Authority FINAL NOTICE To: Address: Cricket Hill Financial Planning Limited Unit 8a, Maple Estate, Stocks Lane, Barnsley, South Yorkshire S75 2BL Date: 16 February 2011 TAKE NOTICE:
More informationFINANCIAL CONDUCT AUTHORITY DRAFT GUIDANCE POLITICALLY EXPOSED PERSONS
SPCB(2017)Paper 38 20 April 2017 FINANCIAL CONDUCT AUTHORITY DRAFT GUIDANCE POLITICALLY EXPOSED PERSONS Executive Summary 1. The Financial Conduct Authority ( FCA ) has invited the Scottish Parliament
More informationAfter FSA the new regulatory landscape
After FSA the new regulatory landscape Simon Morris Partner - CMS Cameron McKenna LLP 15 th April 2011 What is proposed? Financial Policy Committee create the focus for macro-prudential regulation that
More informationHartlepool and Stockton on Tees CCG Annual Audit Letter On the Audit for the year ending 31 March 2014 July 2014
Hartlepool and Stockton on Tees CCG Annual Audit Letter On the Audit for the year ending 31 March 2014 July 2014 Contents 1. Introduction 2 2. Financial audit 3 3. Value for Money 5 4. Conclusions 6 Appendix
More informationSM&CR Roundtable Questions
SM&CR Roundtable Questions Pollyanna Deane Felix Zimmermann Richard Sims Andrea Finn Laura Allen 27 September 2017 SMCR for insurers and insurance distributors 1. Different approaches SMCR for insurers
More informationConsultation Response. High-level proposals for an FCA regime for consumer credit. Response from the Money Advice Service 1 May 2013.
Consultation Response High-level proposals for an FCA regime for consumer credit Response from the Money Advice Service 1 May 2013 Colin Kinloch Debt Advice Policy Manager Colin.Kinloch@moneyadviceservice.org.uk
More informationMiFID2: Documentation Updates
MiFID2: Documentation Updates Nick Colston Louise Tudor-Edwards FI & AMIF Autumn Legal Update 2017 Introduction what we ll cover today MiFID2 s impact on documentation Legal agreements Internal policies
More informationComplying with the Personal Data (Privacy) Ordinance (Cap. 486) in the insurance industry
Legal Update Insurance Privacy & Security Hong Kong 19 December 2012 Complying with the Personal Data (Privacy) Ordinance (Cap. 486) in the insurance industry Abstract Last month, the Privacy Commissioner
More informationAgency Application Form Apple Underwriting
Agency Application Form Apple Underwriting Apple Underwriting 2 6 Bridge Street, Shotton, Deeside, Flintshire. CH5 1TW. Email : Scott.Woodward@AppleUnderwriting.co.uk Tel : 01244 817077 Or Email : Tasha.Williams@DeesideInsurance.co.uk
More information