General Insurance Article - Deloitte comments on the FCA’s Thematic Review

 Mark McIlquham, insurance partner at Deloitte, said: “The results of this thematic review are consistent with the FCA’s clear focus on the insurance distribution chain and the conduct risk within it, especially in respect of personal lines business.

 “Some distributors of insurance policies may have believed that being an appointed representative (AR) was a lighter touch than being directly regulated. This pronouncement shows once and for all that this is not the case.

 “Getting comfortable with the way that a principle firm oversees its network of ARs enables the FCA to efficiently supervise a significant number of firms selling general insurance.

 “The results of this review demonstrate unequivocally that ARs need to be closely overseen and monitored. Firms need a comprehensive and risk based framework for overseeing their ARs, including take on. Through ongoing monitoring, they will need to ensure that the AR is operating to standards consistent to that of the principle firm and demonstrably within its risk appetite.”