2017年-FCA英国金融行为监管局_packaged_bank_accounts_thematic_review_9页_288kb

Regulator Assessment Summary: Qualifying Regulatory Provisions (FCA TR16/8)

Overview

The FCA conducted a thematic review (TR16/8) on Packaged Bank Accounts (PBAs), assessing how firms implemented the rules introduced in March 2013 under the Insurance: Conduct of Business Sourcebook (ICOBS). The review focused on three main areas: eligibility checks, annual eligibility statements, and complaint handling. The objective was to ensure that customers could determine if the cover was appropriate for their circumstances and had the opportunity to reassess eligibility annually. The review was conducted across the whole of the UK and involved 13 firms that had offered PBAs, with 8 firms still selling them.

Key Areas of Focus

1. Eligibility Checks

• Firms must ensure customers are eligible for each insurance product.
• Some practices were found to be insufficient, with potential risks of non-compliance.
• Firms that ask specific questions about medical conditions or use an interactive sales process are considered best practices.

2. Annual Eligibility Statements

• Firms must provide clear and informative annual statements to customers.
• Some firms did not adequately engage customers with these statements, suggesting room for improvement.
• Firms that test and improve the clarity and impact of these statements may benefit from better customer understanding and satisfaction.

3. Complaint Handling

• The review highlighted deficiencies in how some firms handled complaints related to mis-selling.
• Firms are expected to identify and remedy recurring issues, as outlined in SYSC3.1.1 and DISP1.3.3.
• Any remediation efforts to address unfair outcomes would be expected to be carried out by firms.

Impact on Business

Firms Affected

• 13 firms in total have offered PBAs.
• 9 firms have a back-book of PBA accounts.
• 8 firms are currently selling PBAs.

Cost Breakdown

Main Costs and Benefits

Costs

• Familiarisation and gap analysis cost an average of £12,000 per firm, totaling £160,000 for 13 firms.
• Interactive sales processes may involve IT system upgrades, staff training, and marketing material changes, with an estimated one-off cost of £5.6m.
• Sending eligibility assessments to customers may incur £0.41m per year if letters are used.
• Consumer testing of eligibility statements could cost up to £1.2m for 8 firms.
• Ongoing reviews of eligibility statements and management information may cost £0.54m per year.

Benefits

• Improved customer engagement and understanding through better-designed statements.
• Enhanced compliance with existing rules, reducing the risk of regulatory action.
• Better risk management through improved eligibility checks and complaint handling.
• More effective internal controls and processes, aligning with Principle 3 and SYSC requirements.

Non-Costed Elements

• The review does not create new standards but highlights areas where existing rules may not be fully met.
• Good practices such as regular outcome testing (3.23), second and third line reviews (3.24), and internal information sharing (4.32) are already within existing regulatory frameworks and do not incur additional costs.
• The mis-sale complaint handling remediation is not costed, as it is expected to be handled by firms as part of their compliance obligations.

Conclusion

The FCA’s TR16/8 review aimed to ensure firms are meeting the ICOBS requirements for packaged bank accounts. While the review does not introduce new rules, it identifies areas where firms may need to improve their sales processes, eligibility checks, and complaint handling. The estimated total cost for compliance with the guidance is £6.99m (one-off) and £0.54m (ongoing) for the 8 firms still selling PBAs. These costs are primarily related to system upgrades, staff training, and improved customer communication. Firms that already implement best practices may experience fewer costs, while those with weaker processes may need to invest more to align with the FCA’s expectations.