FCA General Insurance Consumer Duty and Update

Overview

With fewer than 90 days to go until the start of the Consumer Duty the FCA has urged firms to ensure they are ready for the 31 July deadline. Sheldon Mills, Executive Director of Consumers and Competition at the FCA, warned that firms who ignore the Duty or who pose the most harm can expect swift action.

“Our supervisory and enforcement approach will be proportionate to the harm - or risk of harm - to consumers, with a sharp focus on outcomes. We will prioritise the most serious breaches and act swiftly and assertively where we find evidence of harm or risk of harm to consumers. In some cases, firms can expect us to take robust action, such as interventions or investigations, along with possible disciplinary sanctions.”

“The 52 million financial services consumers in the UK rely on the sector to deliver good outcomes, and should be even better protected from harm, particularly in these challenging economic times. The Duty will mean that consumers should receive communications they can understand, products and services that meet their needs/offer fair value, and they get the customer support they need, when they need it.”

The current cost of living squeeze makes it all the more vital consumers get fair value, and this should also benefit the competitiveness of the industry as firms strive to offer the best to compete for customers.

A 13 page letter was sent on 13 February 2023 and on 19 March 2023 a survey was sent by the FCA to 600 firms to check progress. This General Insurance focused session will also include an update on Product Value Assessments where both brokers and insurers have an important role to play

We will also cover the current position on multi-occupancy insurances following intervention by the government and the FCA’s new requirements that were published on 21 April 2023. Under the proposals, leaseholders would be defined as customers of buildings insurance and firms will have to act in leaseholder’s best interests and a ban on selling policies based on commission or remuneration levels. Insurers and brokers will also need to provide more information about policies to leaseholders, including detail of any commission paid.

Learning objectives - by the end of this update you will gain an overview of:-

• What is the new Consumer Duty and what will you have to do;
• A reminder as to current issues when it comes to general insurance:-

• Key aspects of the product governance rule to include product value assessments;
• Present position on multi-occupancy insurances and the ramifications of this for insurers and brokers alike.

Speaker bio

I started my insurance career in 1987 and have worked across the sector including stints at PwC and GISC and have led my own consultancy practice since 2004 working closely with AMII, BIBA and the CII and have provided hundreds of well-received (even entertaining!) talks. I am a recipient of the Thomson Reuters Compliance Personality of the Year Award, the London Market People Award for Legal and Compliance and was Highly Commended in the CII Public Trust Awards in 2021. I am proud to judge various insurance awards and am always being approached for commentary and analysis.

I have been a regular speaker at virtually all of the CII’s local institutes and since the world went virtual I have provided over 200+ events to more than 15,000 insurance professionals and feedback has been superb