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July 2, 2024
In a ‘Consumer Duty’ regulatory world, conflicts of interest remain at the heart of Principle 12 (the ‘Consumer Principle’), the Duty’s three cross-cutting Rules, and Principle 8 (managing conflicts of interest fairly, both between the firm and its customers and between a customer and another client).
The FCA wants to understand whether the flow of revenue from insurers or other sources to intermediaries arranging insurance might unduly influence the intermediary to recommend an insurer or insurance product against the customer’s best interests; or cause an intermediary to improperly perform its duties to its customer.
This Hot TopICS explores examples of good practice and the risks of getting conflicts of interest not quite right. It considers business structures, management and control frameworks, conflicts disclosures, customer understanding, claims handling, sources of business and add-ons including premium finance.
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