Non-Monetary Benefit from Insurer/Lender or Other Product Provider
Wed May 13 2020
As you are aware, as a result from the Addendum to the Consumer Protection Code 2012 (CPC) published by the Central Bank in September 2019, if you are in receipt of a non-monetary benefit from an Insurer/Lender (or other Product Provider) you must ensure it is designed to enhance the quality of the service to the consumer, and is of a scale and nature that it could not be judged to impair compliance with a regulated entity’s duty to act in the best interest of the consumer. To that end we have drafted a sample template (members-area/compliance-support/procedure manuals/template docs) that your firm could use in recording non-monetary benefits.
A non-monetary benefit would include for example
- Attendance at, and participation in, Insurer/Lender (or other Product Provider) conferences, seminars, webinars, and other training events on the benefits and features of products or services you provide to consumers
- Assistance with advertising/branding
- Co-Branded literature
- Hospitality of a reasonable de minimis value, such as food and drink during a business meeting or a conference, seminar, or other training event.
- Industry educational seminars
- Other minor benefits that can enhance the quality of the service provided to consumers and do not impair the firm’s duty to act in the best interests of the consumer.
Obviously, some of the above, such as attendances at events, do not apply in this current environment, however, on-line training or webinars would apply.
We have not included a monetary amount on the template, as this should be considered by each firm on a case by case basis taking into account the size and nature of the relationship. A monetary amount would have to be referenced per person, per event, per product, per year, and so on, and the limit would need to be regularly reviewed and updated.
Should members require any further assistance in this regard, or any other aspect of compliance please email us at firstname.lastname@example.org.