Regulatory Compliance Services

When you come to us for support with your FCA application, we'll ensure everything is completed as quickly as possible and avoiding any delaying errors. From completion of forms to setting up the required systems, we'll be there every step of the way. 

As regulatory compliance services specialists, ICS has considerable experience in helping firms prepare and apply for authorisation. Whether you're a new start-up, experienced broker striking out on your own for the first time or an Appointed Representative, we think you'll find our FCA authorisation service of benefit.

Our aim for this service is to break down the process into small, manageable stages to make this as easy as possible for you. We know from experience that brokers can feel overwhelmed by FCA terminology and the submission system, so we do as much of the form-filling for you as possible. All of our consultants are familiar with the FCA Connect system and can support in this way.

We also cover application for Senior Manager status, including the setting up of all processes and even training if required.

Our getting FCA authorised service includes:

• Determining the different FCA forms that will be relevant to the firms application
• Help completing application forms and producing supporting documentation eg Business Plan
• Inputting information into FCA Connect system
• Assistance with applying for Senior Manager status
• Setting up relevant systems and procedures including compliance manuals
• One to one advice from a dedicated FCA compliance consultant

Read more about Getting FCA Authorised

In light of Covid-19, and as part of their overall ongoing oversight, the FCA is undergoing work to determine how firms determine the value of the products designed and distributed can expect to be of value to the end consumer - Insurance Product Value.

As part of this work, they have required insurers and other firms regarded as product manufacturers to complete a detailed information request looking at how they assess and monitor their product value. 

The review's main purpose is to assess firms' actions and their customer outcomes in relation to the 2020 guidance, 'Product Value and Coronavirus'. It covers the firms' response to the pandemic, but also wider concerns around governance, conduct and culture that were raised in an earlier study of General Insurance Distribution Chains (FG 19/5).

ICS are able to assist firms in ensuring they can evidence matters such as:

• Products reviews where the firm has made material changes to premiums
• Specific board/committee reports where product vale has been discussed
• Stopping writing new business
• Changing the cover provided
• Management information used to determine value of products
• Remuneration arrangements
• Co-manufacturing agreements
• Claim frequencies and loss ratios

Our FCA assistance in this area covers support to submit the correct information, practice responses before a visit, and on-site support during an investigation. We can also review team or individual files to ensure compliance and ascertain if procedures are followed correctly. 

If you are able to identify areas where your business could be handled better, our experienced consultants can guide you. We gather information from your team, review your processes and documentation and use examples of best practice to illustrate how any improvements can be achieved. 

A report with your prioritised action plan and a full verbal debrief will help you address any issues identified.

Read more about Product Value

The deadline for FCA's Consumer Duty was July 31st 2023, however there are still Brokers who are struggling to meet the requirements. ICS can support you by undertaking an audit or gap analysis of existing processes, and assist in the preparation of the implementation plan. We have supported many firms with Consumer Duty even after the July 2023 deadline, and can work with you to ensure the process is as smooth as possible.

The FCA's Consumer Duty is its response to their ongoing concerns about how consumers are treated and the experience they receive, rather than solely their fair treatment. The FCA expects firms to focus on customer outcomes and how best to achieve a positive experience, considering each customer's needs and tailoring their journey accordingly.

There is a significant amount of work to be undertaken by firms to plan and initiate any changes required to the customer journey, documentation and management information, in addition to existing deadlines for product governance documentation and reporting. Any firm wishing more assistance with the Consumer Duty should contact us asap.

In summary, the four required outcomes of the new Consumer Duty rules according to the PRIN 2A are:

• Products and Services: all products and services for retail customers to be fit for purpose, designed to meet consumers’ needs, and targeted at those consumers. 
• Price and Value: consumers to receive fair value. This outcome is very much in line with the FCA’s insurance pricing ‘fair value’ requirement.
• Consumer Understanding: firms’ communications must support and enable consumers to make informed decisions about financial products and services; consumers must be given the information they need, at the right time, and presented in a way they can understand. Similar requirements are already in place in ICOBS.
• Customer Support: firms must provide a level of support that meets consumers’ needs throughout their relationship with the firm.

Read more about Consumer Duty

For firms selling:

Improving regulatory health is something we do for all our firms on an ongoing basis, but when a firm plans to refinance or sell in a specific timeframe then we work with them to identify areas where value can be impacted. Our practical and confidential advice aims to lower the acquisition risk of a business while maximising value to your investor(s). 

Increasing buyer confidence by shaping up your systems, controls and procedures in these areas makes for a more attractive vendor and potentially a higher valuation and more competitive sales process. 

Regulatory compliance issues that can affect value include:

• lack of non-financial management information
• approach to, and administration of client money
• how client files are maintained
• culture
• data and IT controls
• PI risks
• treatment of clients and, in particular, approach to delivering fair value and the FCA Consumer Duty

For firms acquiring:

Due diligence is a critical step when buying an intermediary, involving a comprehensive investigation and assessment to understand its financial, operational, regulatory, and legal status. We're often asked to conduct regulatory due diligence in three scenarios:

1. At the point the acquiring firm has signalled it’s intention to buy but before the completion of the Sale & Purchase Agreement;
2. Before the vendor wishes to signal his intention to sell in the market generally, in preparation; and
3. As part of the succession planning of the intermediary where they wish to understand what they need to do to improve the regulatory health of their business, knowing they have some time to make the required changes.

Read more about Pre-Acquisition Due Diligence

Becoming an Appointed Representative of another authorised entity is often the first step towards becoming an insurance broker. The process can be can be a quicker, less costly option than direct authorisation, making it a very appealing when you're keen to begin trading quickly. Support for Appointed Representatives is a key part of our regulatory compliance services.

However, with a few years experience you may want to begin thinking about direct authorisation and whether it is right for you. 

The benefits of direct FCA authorisation are:

• Autonomy of decision making and to progress the business in the direction the firm requires without approval from the Principal
• You can independently establish insurance arrangements and wider third party arrangements without agreements first being in place with the Principal
• You can take a proportionate, risk based approach to setting your compliance framework and systems and controls and not a one size fits all approach determined by the Principal
• Reduction in payaway of fees and commissions to Principal

Applying for FCA authorisation is not as challenging or as costly as you might think. ICS has considerable experience assisting firms in a variety of different ways, from extensive support completing all the documentation to reviewing and editing what firms have already prepared (and everything in between).

With ICS helping you on your journey to direct authorisation, you will have support to complete your forms and documentation, help to set up your required systems and controls and more. We'll ensure the process is completed as quickly as possible while avoiding errors and delays.

Read more about Appointed Representatives

When it comes to regulatory compliance services, staff training is a key part of ensuring the continued professional development of your team. ICS offers both face to face and digital online training solutions through our Compliance E-Learning Platform.

ICS have experienced compliance consultants who have delivered group and one to one training and examples of recent events include:

• Webinars to clients on regulatory developments
• Annual refresher training on regulatory requirements to a UK wide team of broking executives
• Financial Crime awareness training to staff
• Compliance Officer role training to new recruit

Please contact us at enquiries(at)insurancecompliance.co.uk if you would like to discus Conduct Rules training or any other regulatory training requirements you might have.

Read more about Staff Training

As part of our regulatory compliance services, our Corporate Responsibilities Service will help your firm to review its governance arrangements and identify and address any weaknesses in board structure and performance or business systems and controls. It can also provide robust and effective risk identification and management systems and help plug skills and competence gaps in key staff.

Insurance Compliance Services can help with Corporate Responsibilities through:

• Corporate governance
• Systems and controls
• Identifying, assessing and managing risk
• Personal mentoring, training and development

To discuss how our Corporate Responsibilities Service can help your business please call us on 01892 539600 or email enquiries to us at: enquiries(at)insurancecompliance.co.uk

Download our corporate responsibilities brochure

Read more about Corporate Responsibilities

As an industry, Insurance has lagged in terms of getting their HR landscape truly fit for purpose. This is now recognised by the FCA and PRA, who are focusing more heavily on how staff are treated, how companies manage their workforce and how they lead the way to change.

The right HR partner can help you with developing your business strategy, making sure that you have the right people in the right places and they will make sure that whether your goal is to exit, grow organically, or acquire, that you do it in a way which will maximise the opportunities for you whilst you lead from the front.

As part of our Regulatory Compliance Services, ICS offers Insurance HR Support ensuring you have all the basics covered such as employment contracts and employee handbooks, and we can help you build a recruitment and talent management strategy to match your goals and reduce your risk.

Our partners at IHRS have created unique flexible solution for growing your business, for the fraction of the cost of employing a dedicated HR person. The team at IHRS will take on the HR work you need, so that you can get on with what you do best, running and developing your business and your customer relationships.

Read more about HR Support