The FCA has updated its web page in relation to Policy Statement PS21/11 (pricing practices amendments and clarifications) to include updated information about the Senior Manager Attestation, which is designed to allow firms to provide annual confirmation that their firm has complied with the requirements in ICOBS 6B.
Attesting compliance is about senior managers at firms providing an annual confirmation that their firm has complied with the requirements in ICOBS 6B – the pricing remedy / price-walking rules.
The update explains a little more about the first attestation although still does not give the questions that will be in the survey. That being the case firms still don’t know exactly what the Senior Manager will be required to attest to, but the attestation may be that the firm is ready to comply with the new Rules and has all systems and controls in place and to confirm that the firm does indeed provide / sell the core motor and home products (see below).
The FCA will be sending out a Qualtrics Survey Tool survey in January (in which firms can provide their first annual attestation) to all general insurance firms covering:
Add-ons sold alongside home insurance (excluding premium finance)
Add-ons sold alongside motor insurance (excluding premium finance)
Premium finance sold alongside home insurance
Premium finance sold alongside motor insurance
Fees – by charging a fee at renewal for home insurance
Fees – by charging a fee at renewal for motor insurance
Incentives – by giving cash or cash-equivalent incentives to new business customers and is involved in the renewal of either home or motor insurance
Firms subject to the rules must provide this attestation by 31 March 2022.
It appears that the FCA, given that it does not currently fully know who provides or sells motor and home insurance, will send the survey to all insurance firms. Some firms will receive the survey, therefore, that are not subject to the rules.
If your firm is in this group, you need to submit a nil return as confirmation that your firm does not undertake any pricing activity in relation to all products in scope. Further information on how you can do this will be included in the survey, so the survey may well also include an attestation about exactly which types of in-scope motor and home insurance your firm provides or sells.
The FCA is using Qualtrics for the first attestation only. The second and all subsequent attestation will be done via RegData.