Consultation Paper on the Code of Conduct for Authorised Insurance Representatives (2016-12-06)

Summary

This is a consultation paper issued by the Guernsey Financial Services Commission proposing revisions to the Code of Conduct for Authorised Insurance Representatives, which sits under the Insurance Managers and Insurance Intermediaries (Bailiwick of Guernsey) Law, 2002. It follows a 2015 thematic review into general insurance add-on sales and industry workshops, and sets out a full revised draft Code in Annex 1 for comment. It does not itself create binding rules; it invites feedback before the Commission finalises the Code.

• Add-on policies: Clarifies expected standards for selling add-on insurance policies.
• Sales channels: Extends standards to all sales channels, including face-to-face and online/electronic means such as automated websites and apps.
• Customer tailoring: Requires tailoring of information gathered from, or given to, customers based on their insurance experience and knowledge.
• Principles of Conduct: Clarifies that the Principles of Conduct of Finance Business apply to the authorised insurance representative as an individual.
• Structural changes: Expands the introduction (application, background, legal framework) and interpretation sections, and adds guidance notes throughout for clarity and consistency with the Insurance Intermediaries (Conduct of Business) Rules 2014.

The draft Code (Annex 1) covers integrity, skill/care/diligence, training and competency, conflicts of interest, gathering and giving information to customers, renewals, and additional requirements for long term pure protection products. If approved following consultation, the Commission proposes the revised Code take effect on 1 March 2017.

Key obligations

• Interested parties wishing to comment must submit responses to the Commission's Conduct Unit by 17 January 2017, referencing section numbering in the proposed Code where relevant.
• Respondents should indicate whether they consent to their name (or firm name) being included, in anonymised summary form, in feedback on responses received.

Applies to

licensed insurance managers, licensed insurance intermediaries, authorised insurance representatives

Deadlines

• 17 January 2017: Deadline for submitting comments on the consultation paper and proposed revised Code.
• 1 March 2017: Proposed commencement date for the revised Code of Conduct for Authorised Insurance Representatives, if approved.