Focus for the CBI in Respect of Intermediaries

Thu Jun 1 2023

The Central Bank have advised that they are encountering re-occurring issues with Intermediaries in respect of:

  • the submission of annual returns,
  • issues with firms not having PII or not having correct levels or where there are gaps in cover and,
  • general non-compliance with aspects of the code such as suitability.

As previously outlined at the Intermediary roadshow, the Central Bank now operate a 3-strike rule, whereby if a firm fails to satisfy the following requirements three times the Central Bank will commence revocation process:

    • Submit their annual return on time.
    • Have sufficient PII cover.
    • Positive net asset position.

The Central Bank has advised that they will be commencing thematic inspections (desk based and physical) on the sector, these will be commencing soon and will run for approximately a year.  Brokers from all 26 countries, spilt between small/medium/large will be selected.  The selection of intermediaries will also be based on those who pose most consumer harm, i.e., those selling IBIPs/Pensions and focus will be on compliance with the Minimum Competency Code and the suitability requirements of the CPC.



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