FCA Publishes Policy Statement PS17/21 – Insurance Distribution Directive Near Final Rules

This Policy Statement from the FCA provides their response to the feedback received to CP 17/7 on the IDD. It also sets out the near-final rules with regards application, professional requirements, complaints handling and ICOB. For those with responsibility for T&C, please note it introduces the completion of 15 hours CPD each year for relevant staff, some of whom might be Retail Investment Advisers where the 35 hours composition has changed.

Firms are required to comply with these new rules by 23 February 2018. Please click here for:

FCA Policy Statement https://www.fca.org.uk/publication/policy/ps17-21.pdf

IDD – What’s it all about https://www.trailight.co.uk/idd-whats-it-all-about/#more-544



BSB Publishes Certification Regime, Fitness & Propriety Guidance

In February the Banking Standards Board published a statement of good practice and supporting guidance on implementation for the assessment of fitness and propriety of those within the certification regime.

Please click here to download:



CP 17/7 – Insurance Distribution Directive Consultation Paper

This Paper from the FCA consults on changes to the SYSC, TC, MIPRU, IPRU(INV), ICOBS and DISP sourcebooks. It looks to enhance competence by introducing knowledge and ability requirements to be demonstrated by completing 15 hours of CPD a year. A must read for those involved in insurance and reinsurance, intermediaries and other firms in the insurance market – https://lnkd.in/gi_fndW

Are you ready for the 7th March 2017?

The clock is ticking and the 7th March 2017 will soon be with us. This will see a number of conduct requirements introduced to banks and insurers namely:

  • All individuals within significant harm functions are required to be certified as fit and proper to continue to perform that function,
  • Regulatory referencing will form part of the assessment of potential new staff as fit and proper and;
  • All non SM&CR individuals need to aware and trained on the new Conduct Rules.


Fit and Proper

In the majority of firms policies have been designed, and where already existing, reviewed and updated. Processes are in place to produce the certificates and “dry-runs” have been performed ahead of time. Therefore I would urge firms to review the detail of the processes in place. Develop a number of scenarios to assess against the important considerations of whether the individual in your opinion has the honesty, integrity and reputation; competence and capability; and financial soundness to perform their role.

Regulatory referencing

The Regulator has now ensured that responsibility lies with firms to ensure that individuals with a poor track record are identified. This brings with it a number of challenges in demonstrating compliance with the rules, as well as consideration to common law, a desire to avoid discrimination and maintain harmonious employer / employee relationships.

Therefore run through some practical examples; how will you handle an individual challenging a regulatory reference, update the reference records and, if disparate systems or paper records exist, provide references for staff 6 years previous.

Conduct Rules for all other staff

Firms with experience of the implementation of the Conduct Rules for SM&CR staff will have evaluated the training, demonstrating that staff understand the rules and their own responsibilities. This learning can be applied to the wider population.  Furthermore, ask how do you measure compliance with the rules and demonstrate that your culture is working in practice?