Monitoring Appointed Representatives Compliance Adherence for Principal
The Client’s Needs
The client is a specialist professional services and technology firm that works with highly regulated insurance businesses globally. In the UK, it has a large pool of Appointed Representatives and with the increasing regulatory scrutiny of such relationships, was keen to ensure it had an appropriate oversight of these firms.
ICSR was engaged to deliver a monitoring programme of the Appointed Representatives, with a recognition that each undertook different types of work, carrying different levels of risk for the principal. The business included consumer and commercial insurance contracts, some of which were distributed direct to the end-client and others via intermediaries. The client required a pragmatic, proportionate and effective risk mitigation process to be developed and delivered on an ongoing basis.
ICSR collaborated with the client to develop a monitoring process that has allowed the client to gain an understanding of the internal compliance and risk processes utilised within each Appointed Representative of the client. This included:
- An assessment of each individual Appointed Representatives’ compliance and risk processes; and
- Identification of whether the approach adopted by each Appointed Representative was likely to be meeting FCA expectations and requirements.
The work was undertaken by a member of the team with detailed knowledge of the principles governing the oversight of Appointed Representatives and was overseen by a director of ICSR.
The client now has an operational process for the oversight of all existing Appointed Representatives.