SUMMER
COMPLIANCE NEWSLETTER
SUMMER COMPLIANCE NEWSLETTER // BROKER NETWORK
hello and welcome... ...to your Summer COVID-19 Compliance Newsletter. The COVID-19 pandemic has without question changed our society; it escalated at a rapid rate, and nobody could have imagined the challenges that the virus would place on our everyday lives, our families and our businesses. It’s our job as your Network and your Compliance team to support you with any concerns you have. With that in mind, we wanted to bring you a special edition of the Compliance Newsletter to help you to continue to navigate this ‘new world’ we’re all living in, as you provide your clients with the support they need. In this edition, we mainly focus on the temporary rules and guidance that the FCA has introduced in response to COVID-19, which all Members need to familiarise themselves with.
2
Our remote team continues to be here as a helping hand with your regulatory needs, during the crisis and as we emerge from the other side. If you have any specific issues or queries, please speak to your dedicated Risk & Compliance Consultant or the Compliance Helpdesk. I hope you and your families continue to stay safe. Yours,
Donna Walker.
DONNA WALKER Head of Member Risk & Compliance Management
COMPLIANCE NEWSLETTER | VISIT HUB.BROKERNETWORK.CO.UK
meet the team. My days with Broker Network started back in October 1996 when I joined the company as a Data Entry Clerk. At that time, we had just nine Members. I soon decided I’d like to learn more about the world of insurance broking and in November 1999, I was promoted to what was then ‘Compliance & Training Consultant’. Only a short time after, I was presented with a booklet titled ‘GISC Code of Conduct’ to learn in order to assist Members with complying with the rules. The role has now evolved into the current Risk & Compliance Consultant (RCC) and I learn something new every day, with rules changing all the time under the FCA regime. No two days are ever the same as an RCC. One of the key competencies is flexibility and a good sense of humour. There are days when plans just don’t go as you want them to but working amongst a great bunch of people gets you through the challenges. I left Yorkshire behind in 2006 and settled in Hamilton just outside of Glasgow and currently look after 18 Premier and Advantage Members in Scotland and the North East. The role of an RCC is field based, and usually (before the COVID-19 pandemic) I would spend half of my working week out and about visiting Members, completing audits or consultancy work. The remainder of the week was then spent working from home, completing admin tasks, such as report writing, crafting webinars, producing MI or creating guides to help my panel with their regulatory requirements.
The current lockdown restrictions have not had much impact on my day-to-day role. Instead of the face-to-face visits to Members, I am now making full use of technology and have transferred to remote meetings with my panel, either by video or a phone call, which are working well and have been positively received by my Members. For this edition of the newsletter, I have written an article on sanctions checking to highlight the requirements and help you understand your obligations, as well as when to check the sanctions and who to report breaches to.
sam thompson Risk & Compliance Consultant
Click here to read more
COMPLIANCE NEWSLETTER | VISIT HUB.BROKERNETWORK.CO.UK
3
SUMMER COMPLIANCE NEWSLETTER // BROKER NETWORK
your
covid-19 compliance kit
THE FCA EXPECTATIONS DURING THE PANDEMIC
THE FCA’S INTENTIONS FOR THE REST OF 2020
The FCA set out its expectations early on during the onset of the COVID-19 pandemic, ensuring treating customers fairly is high up on the agenda. Firms need to be clear and not misleading whenever they communicate, and they also need to be fair and professional in how they deal with their customers.
In a speech, Megan Butler, Executive Director of Supervision – Investment, Wholesale and Specialists at the FCA, spoke about firms and their responsibilities to clients, the expectations of the regulator and its intentions for the remainder of 2020.
Click here to read more
ARE YOU A KEY WORKER? The FCA has set out steps to help firms identify key workers in financial services. Do you know if you have any key workers?
Click here to read more
COMPLAINTS HANDLING DURING THE CORONAVIRUS Has the Coronavirus pandemic created a negative impact on your usual complaints handling process? The FCA has made it clear that handling complaints remains an important function for brokers.
Click here to read more
Click here to read more
COMPETENCE REQUIREMENTS, CPD AND QUALITY MONITORING DURING THE CORONAVIRUS PANDEMIC Do you know what the CPD requirements are for your business? Are you able to meet the expectations during the Coronavirus outbreak that the FCA has outlined?
Click here to read more
THE EFFECT OF COVID-19 ON PRODUCT VALUE
FCA’S STEER ON HELPING CLIENTS IN FINANCIAL DIFFICULTY The FCA has released final rules and guidance to help your clients who are experiencing financial difficulty during the current pandemic, settings out its expectations for businesses.
Click here to read more
HOW TO HANDLE POST AND PAPER DOCUMENTS Have you been able to fulfil your postal and paperbased process requirements during the Coronavirus outbreak? The FCA has released a statement on how firms should handle this.
Click here to read more
PERIOD TO ARRANGE COVER FOR SENIOR MANAGERS EXTENDED DUE TO THE CORONAVIRUS
Click here to read more
GUIDE ON REVIEWING FEES AND MAINTAINING A FEE STRUCTURE Could the current climate we find ourselves in mean that insurers reduce their commissions to insurers to combat their own financial difficulties? And, if so, what can businesses do to maintain their income? Could firms consider increasing their fees and how do firms ensure they are treating customers fairly in doing so?
Click here to read more
The FCA has confirmed it is extending the maximum period firms can arrange cover for a Senior Manager without being approved from 12 weeks to 36 weeks in a consecutive 12-month period.
Click here to read more
Customers should expect value from the products they buy; and, during this current period of economic uncertainty, insurance brokers should consider the impact the Coronavirus has had on the value of the insurance products they offer.
STAY ALERT FOR SCAM FCA EMAILS Boris Johnson is not the only one that recommends that you stay alert; don’t get caught out by the fake FCA “Due Diligence” email.
Click here to read more COMPLIANCE NEWSLETTER | VISIT HUB.BROKERNETWORK.CO.UK
5
SUMMER COMPLIANCE NEWSLETTER // BROKER NETWORK
don’t forget... HOW DOES YOUR BUSINESS CONTINUITY PLAN STAND UP?
No matter the size or complexity, all firms should have a Business Continuity Plan (BCP) which is ‘fit for purpose’ to maintain ‘business as usual’ should anything unexpected happen. Does your firm have a BCP and is it robust?
Click here to read more
HAVE YOU COMPLETED YOUR CONDUCT RULES TRAINING YET? After the introduction of Senior Manager and Certification Regime (SM&CR) on 9th December 2019, Members should have ensured that all preparatory work has now been completed and implemented.
Click here to read more
HOW MUCH VALUE AS A BUSINESS DO YOU PUT ON TRAINING? The requirements under the Insurance Distribution Directive (IDD) stipulate that staff need to be able to evidence at least 15 hours (35 hours for certified CII staff) CPD each year. Are you confident that your people are competent in their role and do your senior managers understand the role they play in your employees’ training?
Click here to read more
6
COMPLIANCE NEWSLETTER | VISIT HUB.BROKERNETWORK.CO.UK
HAVE YOU COND 2.4 APPROPRIATE RESOURCE – HAVE YOU CONSIDERED YOUR STAFF, PREMISES, CUSTOMERS AND FINANCES? With the continuing economic uncertainty, the FCA is seeking reassurances from intermediaries that they are investing sufficient time and energy into their appropriate resource requirements.
Click here to read more
HAVE YOU REGISTERED FOR THE FCA’S NEW DATA COLLECTION PORTAL REPLACING GABRIEL? The FCA will be moving to a new data collection platform which will replace Gabriel. In preparation for the move, the next time a user logs into Gabriel, they will be asked to complete a compulsory one-time registration activity. Have you done yours?
Click here to read more
DO THE PROPOSED FCA FEES AND LEVIES AFFECT YOU? The FCA has released its Policy Statement regarding its proposed fees and levies for 2020/21. To see how this could have an effect on your business click here.
COMPLIANCE NEWSLETTER | VISIT HUB.BROKERNETWORK.CO.UK
7
need help? Get in touch with the Compliance Helpdesk on compliance@brokernetwork.co.uk or 01423 877839.
20-040 J V3