Round Up Autumn 2018

10 Appointed representatives The IDD introduces new requirements related to your obligations when appointing and monitoring appointed representatives (ARs). You will need to; -- Make sure the AR is keeping appropriate records to demonstrate they are complying with the good repute requirements for staff involved in insurance distribution. -- Ensure the AR is complying with requirements in relation to minimum knowledge and ability of staff. -- Obtain information on the ownership and close links of the AR. Introducer appointed representatives (IARs) If your firm has any IARs there’s a new exemption which will mean those that merely pass on contact details by way of introduction may no longer need to be registered as IARs with the FCA. You will need to decide whether the limit of their activities will enable them to fall within the scope of this new exemption. The following examples of introducing activities wouldn’t fall within the scope of the new exemption: - Actively encouraging clients to refer to your firm for insurance related services - for example, lead generation activities. - Gathering and passing on more than just basic contact details. 6 5 Do I need to bother? The IDD may be seen as a poor relation of MiFID II, or even its unwanted offspring. The two are closely related. If you’ve already suffered the pain of MiFID II and GDPR, you should be getting used to it by now. Here are some common misconceptions about the IDD and things to think about: If I’ve implemented MiFID II I don’t need to do anything. Wrong. While there are several elements of the IDD that mirror MiFID II, some application of the requirements is different. There are also additional requirements. I’m not an insurance broker, it doesn’t affect me. Wrong again. It affects all insurance products including investment based ones such as investment bonds. Do I need to do ongoing suitability assessments for all products? No. Only for insurance based investment products where you have agreed to provide an ongoing service.