New rules and regulations affecting the insurance sector are already starting to exert pressure to put customers first. With the Insurance Distribution Directive (IDD), the Senior Manager and Certification Regime (SM&CR) and other FCA business plan priorities, this pressure is likely to increase. The expectations on the insurance sector are likely to soon equal those experienced by the banking sector in recent years.
Relating to the implementation of IDD in October, PS18/1 states very clearly that providers must “act honestly, fairly and professionally in accordance with the best interests of their customers”. There is little doubt of the FCA intention here, to raise the customer centric agenda and fulfil one of their chief tenets, to protect consumers. Specific key areas of IDD include ensuring that products meet customer needs and that complaints are effectively managed. This includes redress being paid where appropriate, including out of court settlements. These stated aims present the threat of enforced remediation and the opportunity for providers to undertake proactive rectification ahead of problems being raised by the FCA.
A recent high-profile action by the regulator is a clear indicator that they are prepared to use enforcement where providers fail to meet their expectations. In this case, a provider failed to be transparent with its customers regarding premiums and failed to encourage them to shop around at renewal time. For the provider in question, this resulted in costly remediation activity, disruptive customer contact and consequential reputational damage with the public and the FCA.
Whether motivated by FCA action, a thematic review or more proactive efforts to stem future complaints, past business reviews typically stretch normal capacity and capability. The demand for additional and specialist resource may be beyond what a provider is able to recruit and manage for themselves.
RFS is expert in resourcing skilled teams and the design and delivery of specialist projects. This experience includes helping a leading MGA group successfully conduct a past review of consumer sales, refining complaint procedures for a top 10 independent broker and supporting several intermediaries & product providers through Section 166 actions. RFS also bring the independent lens of an expert third party. This gives a wider view that is industry benchmarked and meets best practice; leading to business improvement and competitive advantage.
At RFS we also focus on building operational advantage. Through analysis and insight, we develop the most effective processes, which we ensure are transferred to BAU at project close. Stringent policies and procedures also ensure robust governance that stands up to regulatory rigour.
RFS is in a strong position to support insurance providers scope, set-up and deliver; deploying quickly and scaling up and down as workflow demands. To find out more how RFS can help you with past business reviews please get in touch with us. As well as supporting providers with resource only solutions we also offer fully managed services with assurance over quality performance and productivity.