2017年-FCA英国金融行为监管局_thematic_review_provision_of_premium_finance_to_retail_general_insurance_customers_4页_126kb

Regulator Assessment Summary: Qualifying Regulatory Provisions

Overview

Title of Proposal: Thematic Review: Provision of premium finance to retail general insurance customers (TR15/5)
Lead Regulator: Financial Conduct Authority (FCA)
Date of Assessment: 24 February 2017
Commencement Date: 11 May 2015
Origin: Domestic
Cutting Red Tape Review Implementation: No
Affected Areas: Whole of the UK

This assessment focuses on evaluating how general insurers and insurance intermediaries meet the information needs of retail customers when using premium finance to purchase general insurance products. It is not intended to introduce new regulatory standards or obligations, but rather to highlight existing non-compliance issues.

Core Content

The thematic review was conducted to assess compliance with long-standing regulatory requirements among 13 general insurers and 30 insurance intermediaries. It aimed to identify areas where firms failed to meet the FCA's expectations regarding customer information and transparency in the context of premium finance arrangements.

The review emphasized the importance of ensuring that customers are fully informed at appropriate stages of the purchase process. This includes:

• Comparing the cost of insurance via upfront and instalment payments.
• Understanding any additional costs associated with instalment payments.
• Being aware of the implications of entering into a credit agreement.

These expectations are derived from existing FCA rules and guidance, specifically:

• ICOBS 6.1.5 and 6.1.6G: Mandate that firms provide customers with clear and timely information to make informed decisions.
• PRIN 6 and 7: Emphasize treating customers fairly and meeting their information needs.
• CONC and Consumer Credit Act (CCA): Require transparency in credit agreements and financial promotions.

The review also highlighted the need for firms to disclose their role in premium finance, the nature of the service, and any fees or commissions involved. This is in line with CONC 3.3, 3.7, 4.4, and other relevant sections of the FCA Handbook.

Key Information

• Number of Firms Affected: Approximately 3,250 general insurers and insurance intermediaries.
• Familiarisation Costs: Estimated at £156,000 based on the assumption that each firm requires 1 hour of reading time for the 5,666-word report and that compliance staff are paid at £48/hour.
• Remediation Costs: Estimated at £0. The review does not introduce new rules or guidance; it simply reminds firms of their existing obligations under the FCA Handbook and relevant legislation. Therefore, no additional costs are incurred to meet these expectations.

Main Points

• The thematic review does not set new regulatory standards.
• It reports on the current compliance status of firms with respect to existing rules.
• The expectations outlined are consistent with the FCA Handbook and Consumer Credit Act.
• Firms are expected to ensure transparency and clarity in their communication with customers regarding premium finance and insurance purchases.
• No new obligations are imposed on firms through this review.

Impact to Business

The overall impact is minimal in terms of regulatory burden, as the review does not add new rules or expectations. It serves as a factual report of current non-compliance, with the aim of reinforcing existing regulatory requirements.

Additional Information

• The cost estimate for compliance staff is based on a rate of £48/hour, derived from the 2016 Robert Half salary guide, which estimates an annual salary of £100,000 for a compliance manager in London.
• A link to the Robert Half salary centre for further validation: https://www.roberthalf.co.uk/news-insights/salary-centre-2016