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Latest FCA regulation changes

As you will have heard in the recent press, as a result of an in-depth thematic review by the Financial Conduct Authority on the Appointed Representatives network across the insurance industry, significant changes are now expected for all Principal firms (Insurance Companies) and Appointed Representatives to abide by.



To provide assurance to customers that they are being sold insurance products from individuals who are meeting specific regulatory requirements, there has been a focus by the Financial Conduct Authority (FCA) on how employees within Appointed Representatives (ARs) are assessed as suitable to perform a required role.


What is the key change for you?

One of the requirements imposed by the FCA is that anyone within an AR who is involved in Insurance Mediation Activities (i.e. someone selling or arranging insurance) should be assessed as fit and proper and evidenced accordingly.


What does this mean for you?

Whether you work with us here at Fish Insurance, or another provider, you will already be asking your staff to complete the obligatory annual competency tests on behalf of the insurance company you are working with. These competency tests demonstrate that the person selling or arranging insurance for a customer, demonstrates the knowledge appropriate for carrying out that role.

In addition to this, all of your staff are now required to have the following checks carried out on them:

• A Consumer Credit Check
• A Basic DBS (Disclosure Barring Service) Check


Who do these checks apply to?

• All Directors within your firm
• All Senior Managers connected to the selling of Insurance within your firm
• Any staff selling Insurance within your firm


What should you do?

In some cases, you may already be carrying out these checks for your staff and informing the insurance company you are working with to provide evidence to ensure your staff are ‘fit and proper’ to be selling insurance. In this case, you must now share these checks with your Principal Firm.

If you are not carrying out these checks then you will need to arrange with your partnered Insurance company of how best to do this.

If your staff do not have the relevant checks in place, then they will not be able to arrange insurance until these checks are evidenced and appropriately stored so that you can demonstrate your staff are able to sell and/or arrange insurance. 

How can Fish Insurance help?

As we have been working closely with the FCA throughout this Thematic Review of ARs, we already have a process in place where Fish Insurance pay for these checks to be administered for all relevant staff. These checks will also form part of our annual audit for all our Appointed Representatives. Where possible we will take the hassle and administration out of this significant change to your business.


What happens if you don’t want the checks to be carried out?

As this is a regulatory requirement by the FCA, you will no longer be able to retain the Appointed Representative status due to the considered risk posed to the consumer should you object to the tests. This, in turn, means that you will not be able to sell/arrange insurance for your customers.



If you would like to find out more about the latest regulation and ensure that you are able to continue as an Appointed Representative on behalf of your partnered Insurance company, then please contact them at your earliest convenience.

Alternatively, here at Fish we have an internal Compliance team, who will be more than happy to guide you through the process and explain how Fish can make this process as simple as possible for you and your staff.


If you have any questions at all about the latest changes to Appointed Representatives and the expectations placed upon them by the FCA, then please do contact a member of our Business Partnerships team.

About our team

Our Business Partnerships team are happy to discuss how we can work with businesses just like yours to provide your customers with affordable insurance cover.

Useful Links
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The Financial Conduct Authority (FCA) website contains lots of information and explains the complicated regulations.

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