Are you ready for the SRA Amendments to Regulatory Arrangements (Insurance Distribution) Rules 2018?
The new rules take effect from 1 October 2018 and implement the requirements of the EU Insurance Distribution Directive.
The new rules take effect from 1 October 2018 and implement the requirements of the EU Insurance Distribution Directive. Law firms, as exempt professional firms (EPFs) on the FCA register are classed as ancillary insurance intermediaries (AIIs) by the SRA, where:
- The firm’s principal professional activity is not insurance distribution
- The firm only distributes certain insurance products which are complementary to a good or service
- The insurance products concerned do not cover life assurance or liability risks, unless that cover complements the good or service which the intermediary provides as its principal professional activity.
The main changes that will affect firms, and it will primarily be those firms dealing with PI, conveyancing and probate that the changes are relevant to, are:
- Insurance mediation activities are now called insurance distribution activities
- An insurance distribution officer will need to be appointed who will be responsible for insurance distribution activities – firms should already have an insurance mediation officer if carrying out insurance mediation activities
- A firm carrying on/proposing to carry on insurance distribution activities will need to notify the SRA in the prescribed form – but this does not apply to a firm registered on the Financial Services Register and able to carry on insurance mediation activities before 1 October 2018
- Staff will need to have appropriate training and be DBS and bankruptcy checked
- Information to a client should be provided in good time
- There are requirements relating to services provided over the telephone
- What information should be given to clients when other products or services are provided as part of a package or in the same agreement with an insurance product.
The SRA has said it will continue to develop guidance.
If you have not yet amended your documentation and website and need some advice, please contact us.
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