2017年-FCA英国金融行为监管局_tr15_7_delegated_authority_outsourcing_in_the_general_insurance_market_2页_164kb

Regulator Assessment Summary: Qualifying Regulatory Provisions

Overview

The document outlines the findings of a thematic review conducted by the Financial Conduct Authority (FCA) titled "Thematic Review: Delegated authority: Outsourcing in the general insurance market (TR15/7)". The review was carried out in March 2017 and commenced on 2 June 2015. It focuses on the oversight of outsourcing arrangements in the UK general insurance market, particularly concerning the delegation of underwriting and claims handling authority to third parties.

Scope and Affected Areas

• Type of business affected: General insurers and insurance intermediaries that engage in outsourcing arrangements.
• Estimated number of affected firms:
  • General insurers: 400 firms (including those operating on a Passporting basis)
  • Insurance intermediaries: 5,200 firms (including Managing General Agents)
• Geographic scope: The entire UK

Core Content and Main Findings

The thematic review aimed to evaluate the compliance of firms with existing regulatory requirements related to outsourcing. It specifically looked at:

• The outsourcing arrangements of 12 insurers
• The activities of 19 firms that held underwriting and/or claims handling authority from those insurers

Key points from the review include:

• The external delegation of underwriting authority and other significant functions such as claims handling is defined as outsourcing and thus subject to the relevant rules and guidance in the FCA Handbook, particularly Management Arrangements, Systems and Controls (SYSC).
• The review did not introduce new or additional rules but clarified the interpretation of existing ones.
• The findings highlight potential shortcomings in firms' oversight of outsourced activities and their impact on customer service and product delivery.

Cost and Benefit Analysis

Familiarisation Costs

• Report length: ~14,725 words
• Reading time: ~2.5 hours per person
• Assumed readers per firm:
  • 3 people per general insurance firm
  • 1 person per insurance intermediary or MGA
• Estimated total familiarisation costs:
  • General insurers: 400 firms × 7.5 hours × £48 = £144,000
  • Intermediaries/MGAs: 5,200 firms × 2.5 hours × £48 = £624,000
  • Total: £768,000

Remediation Costs

• The review did not impose new standards or rules, so no new remediation costs were estimated.
• However, the report notes that some firms may incur incremental one-off and ongoing costs to achieve compliance with SYSC rules, particularly those that were not fully compliant before the review.
• These costs were not quantified due to the retrospective nature of the assessment and the lack of data collection during the review period.
• The FCA also states that compliance with previously existing rules is not part of the impact assessment under the Enterprise Act, to avoid double-counting.

Total Estimated Impact

• Total familiarisation and gap analysis costs: £3,840,000
• Note: This includes both the initial familiarisation costs and the associated gap analysis for compliance.

Additional Information for BIT Score Validation

• BIT Score: 0.5
• Business Net Present Value: -0.77
• Net cost to business (EANDCB): £0.1 million
• Implementation date: 2 June 2015
• Duration of policy: 10 years

Supporting Resources

• Thematic Review Report: TR15/7 - Delegated authority: Outsourcing in the general insurance market
• Robert Half Salary Guide (2016): Salary Centre - Financial Services

Key Takeaways

• The FCA clarified that outsourcing, including the delegation of underwriting and claims handling authority, is subject to SYSC rules.
• The review focused on assessing existing compliance rather than introducing new regulations.
• The estimated cost for familiarisation and gap analysis is £3.84 million, primarily driven by the need for firms to understand and apply the review findings.
• Remediation costs were not quantified, as the review did not establish new compliance requirements.
• The BIT score of 0.5 indicates a moderate impact on business, with a net cost of £0.1 million over a 10-year period.