4. 4
WHAT IS ALL ABOUT ?
11 February 2020
WHAT THE FCA IS
TRYING TO
ACHIEVE?
WHAT THE FCA IS
SAYING?
HOW DO THEY GO
ABOUT IT?
Protecting Consumers from
Harm
• Buying unsuitable or mis-sold
products / services
• Important consumer needs
are not met
• Prices too high / quality too
low
• “Our view of the General
Insurance (GI) sector overall is
that there are significant risks
of harm “
• “we require firms to deliver a
step-change in their culture “
FCA Portfolio Strategy for Insurers, Letter 8th January
2020
BIBA speech, May 2019
Business
Model
& Strategy
Culture
&
Governanc
e
6. 6
TOP 3 AREAS FOR GENERAL INSURANCE
11 February 2020
PRODUCT /
DISTRIBUTION
PRICING
PRACTICES
SALES
• Ultimate value that customers
received from products and
services
• Control over the remuneration
they receive
• Roles and remuneration of the
various actors in the value
chain
• Oversight of delegating
authorities
• Impact of distribution strategy
Fairness in pricing practices
• Oversight of pricing
• Propensity model
• Differential pricing
• Potential Discrimination
• Communication
• Complaints / FOS
• Demands & Needs
• Suitability of advice
• Communication
• Phone / Web / Face to Face
• Premium Finance
7. 7
ADDITIONAL 3 AREAS FOR BROKERS
11 February 2020
CONFLICT OF
INTEREST
CLIENT MONEY
UNRATED
INSURERS
DUE
DILIGENCE
• Product Providers
• Wholesale Brokers
• MGA
• Retail Distribution
• Follow the rules
• Audit quality
• Fraudulent behaviours
• It is about the service you
provide
• Know Your Insurer (KYI)
• Advised / Non-Advised
• Existing / New Client
• Concentration risk
9. 9
BUSINESS MODEL REVIEW
11 February 2020
BUSINESS MODEL
SUSTAINABILITY
Revenues &
Profit
Sharing
Premium
Finance
Add-Ons
Fees &
Charges
Income Streams
Other
Income
10. 10
FOCUS ON PEOPLE
11 February 2020
INDIVIDUAL
ACCOUNTABILITY
• Clarity about who does what
• Training & support – Fit & Proper
• Initial and future impact of the
regime
• healthy (or not) tension
• non-financial misconduct
• M&A transactions
• Individual careers