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Insurance Distribution Directive implementation (PS17/21) – Feedback to CP17/7 and near-final rules

On the 25 September I sent GIG FCA’s third IDD CP. At the same time FCA has also released their first Policy Statement setting out their near final rules for their implementation of the IDD. This can be found here.

This Policy Statement sets out their near final rules based on the feedback they received to CP17/7 (FLA’s response is attached). It covers:

  • the scope and application of the IDD, including the regimes for ancillary insurance intermediaries
  • professional, organisational and prudential requirements for insurance distributors
  • complaints and out-of-court redress
  • conduct of non-investment insurance and pure protection business

Who this applies to

This Policy Statement will affect a large number of firms and will be of direct interest to FLA members as it covers professional firms involved in insurance business (both authorised and exempt) and ancillary insurance intermediaries (including those excluded from regulation through the connected contracts exclusion). In this respect,  Chapter 6 – looking at Ancillary insurance intermediaries – is likely to be of most interest. Paragraphs 5.50-5.56 (looking at Cross-selling (ICOBS 6A)) are also likely to be of particular interest.

Firms need to continue with their preparations for the application of the IDD on 23 February 2018. Please note we raised this timescale as one of our issues and concerns but there hasn’t been any shift on this tight timescale (to be fair this has been driven by the EU).

Next steps

FCA intend to publish their next Policy Statement in December 2017. This will cover rules for product oversight and governance, conduct rules for insurance-based investment products and the new Insurance Product Information Document (IPID).

Please note we will also briefly cover off these latest publications during our IDD update from Malcolm Padgett at our next GIG committee meeting on Friday 29 September.