London Market

Specialist Compliance Services for The London Insurance Market

ICS London Market is a specialist arm of Insurance Compliance Services and provides a full range of specialist compliance services to Lloyd’s and other (re)insurers and distributors.

This includes helping Managing Agents, insurers and (re) insurers meet their regulatory obligations and manage all aspects of Conduct Risk. Our insight and expertise add value far beyond simple regulatory compliance. We combine a rigorous knowledge of every nuance of current regulation with a detailed understanding of the workings of the Lloyd’s and London Insurance Market.

  • Our understanding of distribution (routes to market) informs our coverholder audit and due diligence services.
  • Our product documentation review service is underpinned by comprehensive specialist product knowledge.
  • Hands-on London Market underwriting experience feeds into our independent underwriting review service.
  • Our extensive knowledge of product servicing in the London Market means we are ideally placed to carry out audits of claims TPAs.
  • We understand customer service and the need to excel at this in a customer centric environment, so we are perfectly placed to advise on implementing compliant complaints processes.

An independent review helps insurers in maintain a corporate culture that ensures customers in the distribution chain are treated fairly at all times (the ‘customer experience’), which should ultimately have a positive impact on investors’ return on equity.

No matter the challenge, we focus on delivering practical and enduring solutions that equip our clients to operate in a compliant culture.

Download our London Market Brochure, and if you have any questions or would like to make an enquiry about our ICS London Market services please get in touch.

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How Can ICS London Market Help You?

While audits, documentation reviews and independent underwriting reviews make up a significant proportion of the work ICS London Market undertakes for clients in the London Market, we also deliver a wide range of other services.

Obvious examples would include work on complaints processes and systems, on insurance distribution, or on product oversight groups.

If we haven’t talked in detail about particular Regulatory Compliance Services you are looking for, please don’t hesitate to ask; there’s a very good chance we can help. Whatever London Market compliance-related services or advice you may be in need of, why not talk to one of our specialist consultants today.

To find out more about how we can help call us on 07874 864905 or email enquiries(at)insurancecompliance.co.uk.

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Specialist London Market Services

ICS London Market offers a full range of audit, review and independent assurance services. A key area of work for ICS London Market is providing auditing services for Managing Agents and other (re)insurers who delegate, or are considering delegating, underwriting or claims authority to UK or European-based third parties. In addition to this we also offer documentation reviews and independent underwriting reviews. Click the headings below to find out more:

An auditing service provided to Lloyd’s Managing Agents and other (re)insurers who delegate, or propose delegating, underwriting and/or claims’ authority to a third party based in the UK or Europe. The auditing service will establish if the firms’ assuming delegation are operating within the terms of their binding authority or TPA agreement, and have adequate capabilities, controls & systems and comply with applicable regulatory rules.

Our team has London Market underwriting experience that understands ‘routes to market’ and appreciates the importance of coverholders in the distribution chain. Our audit conclusions are constructive and focus on evidencing; with comment on the corporate culture within the firm being audited.

Our auditors have access to a dedicated team that provides advice and guidance on insurance mediation. Amongst other things, this resource has extensive “front end” knowledge on the sales, distribution and servicing aspects of the London Market Conduct Risk proposition. This knowledge and experience within the team, enables our audits and due diligence to identify and evidence these important Conduct Risk factors.

The Conduct Risk principle requires that insurers have effective systems and controls for proactively managing the delegation of underwriting and/or claims’ authority. This risk management includes due diligence of prospective coverholders/TPAs and audits once authority has been delegated.

Engaging with us gives the insurer control of a scalable and consistent audit process, depending on the insurer’s risk assessment of the entity and the insurance/reinsurance business concerned.

Amongst other things, our audits and due diligence cater for:

  • Coverholders and TPAs operating in the UK or Europe
  • Worldwide Risk Locations (regulatory and tax)
  • Insurance and reinsurance
  • All types of delegation from prior submit to full authority
  • Sub-delegation
  • Wholesale and retail coverholders
  • All customer classifications (Consumer, Commercial, Large Risk & Reinsurance)
  • Micro-enterprise customers
  • Electronic trading
  • Lloyd’s coverholder audit scopes (2014 & 2018 versions) or bespoke scopes
  • Extended scopes for audits of claims’ TPAs
  • Audit report formats as required
  • Communication with our Principal during the audit process, where necessary.

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Would your policies or policy wording documents benefit from an independent review?

ICS London Market has the expertise and experience of working on Conduct Risk issues for Lloyd’s Managing Agents, MGAs and other insurers. This includes reviewing UK insurance policy wordings and related customer documentation for which the insurer (or applicable product manufacturer) is responsible, to ensure those documents are compliant. We can review existing policies and assist with the design and drafting of policy wordings for new insurance products and, in addition, review product governance and value as required by the FCA.

We have successfully drafted numerous consumer and micro-enterprise insurance policy wordings, and accompanying IPIDs, which are currently used in the UK insurance market including commodity and flexible benefit products. We are currently working with a number of firms to ensure their product governance oversight meets FCA requirements and products designed and distributed can demonstrate appropriate value to the target customer.

Some considerations for the legal contract between the insurer and the policyholder and other customer documentation:

Consumer customers

  • Legally compliant
  • Clear, fair and not misleading
  • Plain English
  • Any delegated authority is clearly shown
  • Document structure
  • Regularly reviewed, including robust root cause analysis to identify systemic issues

Micro-enterprise customers (Lloyd’s)

  • Lloyd’s and the Financial Ombudsman Service require ‘micro-enterprises’ to be treated as Consumers
  • The Insurance Act 2015 requires that a ‘consumer insurance contract’ has the meaning as defined in the Consumer Insurance (Disclosure and Representation) Act 2012; i.e. the Act classifies ‘micro-enterprises’ as Commercial customers

Therefore, Lloyd’s insurance policies for micro-enterprise customers have to be blended to fulfil their Consumer status and comply with the Insurance Act 2015.

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An independent underwriting review is an effective risk management tool.

ICS London Market has an underwriting resource to perform independent underwriting reviews for Lloyd’s Managing Agents and other (re)insurers.  Such external and independent reviews are now an integral part of the underwriting control process; independent reviews along with peer reviews, are recognised as an effective risk management tool to protect the balance sheet.

Our consultant has significant underwriting experience which, if necessary, allows effective challenge of the (re)insurers’ underwriters. The reviews will be undertaken through a “terms of reference” that specifies the review criteria. This scope can be as extensive as the nature of the business requires and can include the reviewer making the risk selection for review activity.

Our independent underwriting reviews can be applied to worldwide insurance or reinsurance (proportional or excess of loss) portfolios, for most non-marine classes.

Engaging with ICS London Market, facilitates a truly independent aspect to a (re)insurer’s detection controls. The following considerations are included in the review, as required:

  • Correct and consistent application of the (re)insurer’s: strategies, pricing and underwriting policies
  • Writing within the terms/limitations of outwards reinsurance
  • Each underwriter is adhering to their terms of reference and authorities
  • Examination of slips, placing information and general file review
  • Risk location
  • Reporting
  • Contract certainty
  • Review findings documented to a consistent standard
  • Direct reporting at Board level

If you have any questions or would like to make an enquiry about our ICS London Market services please get in touch.

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We are perfectly placed to advise on implementing compliant complaints processes.

Do you support customers throughout the lifecycle of a product or service after the point of sale (particularly if they want to make an enquiry, claim, complaint or switch provider)? Do you ensure that your support processes do not lead to unreasonable barriers at a point when customers want to take action? Do your overall consumer support assessments consider consumers who demonstrate characteristics of vulnerability?

As part of the Consumer Duty requirements, these are the types of questions that the FCA expects firms to ask of themselves in relation to the support they provide to customers post sale. They expect all firms in the distribution chain to have appropriate process in place that also take into account, in particular, the impact on customers displaying any form of vulnerability. A key stage in any post sale contact will be when a customer feels the need to make a complaint about the product or service received. It’s at this point that firms should be able to rely on the their complaints processes and the knowledge of their staff to ensure that all complaints are remedied to the complainants satisfaction. However, often there is a failure in the process which leads to the complainant going to the Financial Ombudsman Service to resolve.

To avoid this scenario ICS London Market can review all aspects of a firm’s complaints processes, documentation, management information and staff awareness and provide support to plug any gaps. As part of any complaints work we will also review how recent complaints were handled and offer advice on how these could have potentially been handled better.

Where an insurer has granted complaint handling authority under a delegated underwriting agreement, ICS London Market can ensure that any complaints are handled in accordance with the terms of the agreement and if applicable, the Lloyd’s complaints process.

If you have any questions or would like to make an enquiry about our ICS London Market services please get in touch.

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How Can We Help?

We offer up to two initial consultations without charge, to determine the exact nature of your challenges/concerns. If you would like to try out some of our services before committing we can offer a demo of our Compliance Portal, samples of our Hot TopICS or attendance at one of our Webinars. Thereafter we will agree which of our services are most likely to help you most with your regulatory requirements, agree a package of support (or a one-off project) and submit a proposal for review. Before, of after, you decide to go ahead, we will introduce you to the Consultant(s) who will agree a diary of contact at times to suit you both.

Please call us on 01892 539600, email us at enquiries(at)insurancecompliance.co.uk, or send us a message using the form for more information or to make an enquiry about any of our compliance services.

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DR&P Group have been working with ICS for the last 3 years, supporting the group in several key areas of compliance. Whilst ICS primarily support us on our London Market business following our first Lloyd’s Broker acquisition, they have been able to provide support across a broad spectrum of compliance issues including audits, training and the management of Appointed Representatives.

We have been impressed with ICS ability to interpret regulatory change, their depth of knowledge and most importantly, the way that they complement and work in tandem with our own internal compliance department and our business leaders. Tom Storer DR&P Group
I wholeheartedly recommend the services that ICS provide. ICS, through Elly, has spent time to understand our business and provides guidance and support to negotiate the regulatory landscape. Elly is hugely knowledgeable, approachable, and responsive, and happy to answer questions.

ICS is pro-active in the regulatory space, providing numerous resources including highly relevant bulletins, seminars and webinars. Overall a pleasure to deal with. Specialist Insurance Broker South West England
The guidance received from ICS helped us navigate compliance issues with ease, ensuring that we met all regulatory standards efficiently. The practical solutions they provided have greatly improved our compliance processes and minimised our risk exposure.

We highly recommend ICS to any organisation seeking expert compliance advisory services. Their professionalism, expertise, and commitment to excellence are truly unmatched. Thank you for your support!” Specialist Intermediary South East England
In August 2023 we engaged ICS for compliance advisory services, and the experience has been outstanding. Their deep knowledge and understanding of regulatory requirements have been invaluable to our organisation.

From the very beginning, Elly at ICS demonstrated a thorough understanding of our industry’s unique challenges and tailored her approach to meet our specific needs. In addition, the whole ICS team has been proactive, detail-oriented, and always available to address any concerns or questions we had. Specialist Intermediary South East England
We highly value the regular updates which explain the actions we need to take. These help us anticipate and accommodate regulatory changes and maintain compliance. Insurance Business Owner
We particularly appreciate our dedicated compliance consultant’s visits. He is a key part of our team and helps us feel confident. Insurance Business Owner
We have faith that you will always deliver a high standard of service. Insurance Business Owner
You are always ready to help. Our dedicated consultant gives us tailored advice at our quarterly reviews and the telephone helpline is always available whenever we need a little extra support. Insurance Business Owner
Your 'full service' package gives us unrivalled peace of mind. From the comprehensive compliance manual to the Hot TopICS regulatory updates, you ensure that we are well-informed and able to implement the actions needed to maintain compliance. Insurance Business Owner
Thanks to their regular visits, our compliance consultant is now, in effect, part of our operational team. We are able to contact them at any time, not just when they visit regularly, and they understand not only the questions we ask but what is prompting us to ask them! Insurance Business Owner GSIS Ltd
We have never been more comfortable with our regulatory status / situation based on the support and guidance we receive from you guys. Jeff Rush Chief Executive, Rush Insurance Services Ltd
Earlier this week I was sent details of what would be required for a Network audit at the end of the month. The amount of documents, policies, procedures and registers required for this were terrifying and would previously have taken me 2 weeks of solid work to pull together, whilst still trying to run the business and look after clients. Because of the work Casey had already done for us though, in only 2 visits, literally everything needed was readily available, up to date and perfect. Can’t thank her enough and wouldn’t hesitate to recommend her to anyone else. Insurance Business Owner
ICS has been invaluable to us and we will continue to use them as our external compliance arm as they are a dedicated professional team with unparalleled expertise in the industry. Insurance Business Owner
Since working with ICS we have complete peace of mind regarding all of our compliance needs. We have worked with others in the past who have not understood our business or our needs. ICS’s service has been exceptional, not only with our regular day to day requirements, but also when we have called on them for support and advice for bespoke projects; indeed they attended an urgent meeting with a moment’s notice. Insurance Business Owner
We have used ICS for 10 years. We are extremely satisfied with the service they provide and with their specialist knowledge and advice on the rules and regulations. Nothing is too much trouble. Help from the friendly team with the RMAR/Gabriel is greatly appreciated. We would not hesitate to recommend them. Insurance Business Owner
We have built up a good relationship with our Consultant, who is key to the service ICS provides to us. We find the way he coaches us and understands our mentality helps with the compliance piece – and we are never lectured. Insurance Business Owner
We are very pleased to have been a business partner of ICS for 5 years. This relationship works very well giving us the right balance of internal control and external, up to date advice. The service provided by our relationship manager, Rob Cawthorne, has been professional and beneficial. Rob has also been our main contact for some time now providing stability and continuity. Insurance Business Owner
Really pleased to finally meet up today and get so much done. I feel a lot better knowing what is expected of me as a business owner. Much of the Product Governance and Pricing initiatives are core to my business anyway and I have no trouble with what is in store Insurance Business Owner
ICS worked with Specialist Risk Group on a major project from August 2021 to January 2022. As a company that prides itself on its specialist knowledge we were impressed by the way that ICS understood our business. They managed the entire project efficiently, keeping us updated at each stage of the process. Our dedicated consultant, Tony Darwall, was very experienced and built a good rapport with our staff. The deliverables from the project were of a high quality and we look forward to working with ICS again in the future. Clare Lebecq Group Chief Operating Officer, Specialist Risk Group