Update following Central Bank Intermediary Road Shows
Fri Nov 15 2019
The Central Banks Retail Intermediary Roadshow 2019 slides have been published and you will find them on the Central Bank website here.
I am aware that a number of questions were raised by members at the recent Central Bank seminars in Dublin and Galway in relation to the following two topics:
Commission Summary Document
A key area of focus for Brokers Ireland since the publication of the ‘Addendum to the Consumer Protection Code 2012 – September 2019’ (CPC) has been in respect of Provision 4.58A which requires that intermediaries make available in its public office or on its website (and brought to the attention of your consumer ) a list of all commissions received across all providers you deal with.
Brokers Ireland are aware and share members concerns about the practical problems in compiling this “summary” document, considering the amount of information that is required by the provision, and the fact that this document may run to 100s of pages for many of our members.
Brokers Ireland have met with the Central Bank on this issue in October and will continue to engage with them over the coming weeks to try reach a solution for members. We are also engaging with other stakeholders (such as Product providers/CRM providers) in relation to the requirements.
Brokers Ireland aim to be in a position to issue guidance on this issue to members in the coming weeks, bearing in mind the implementation date of the 31st of March 2020.
Assessing the Financial Soundness of Insurers
Over the past 6 months, Brokers Ireland has had considerable engagement with the Central Bank on the issue of Broker responsibilities in assessing the Financial Soundness of Insurers. It was clear from the Central Bank presentation at the roadshow, that Brokers are not responsible for the solvency of insurers but that it is expected that a certain level of due diligence (proportionate to the nature and scale of your brokerage) is conducted on insurers who you conduct business with.
We are currently developing guidance in this area for members and will be issuing it in due course.
Minimum Competency Requirements
As we approach the end of the year, it is timely to remind members of their CPD requirements under the Minimum Competency Code.
All individuals whether Grandfathered or Qualified are required to complete 15 formal hours of CPD per annum, of which 1 hour must relate to Ethics per year.
Outlined below are the categories of accreditation under the Minimum Competency Code.
- Life Assurance
- Savings and Investments
- Personal General Insurance
- Commercial General Insurance
- Private Medical Insurance and Associated Insurances
- Housing Loans, Home Reversion Agreements and Associated Insurances
- Consumer Credit and Associated Insurances
The content of CPD hours must be directly relevant to the functions of the Grandfathered person, e.g. If as a Grandfathered individual you advise on Life, Pensions, Savings & Investments and Mortgages, then at least one hour of CPD completed must be directly relevant to the functions undertaken i.e. a hour CPD in each of the Categories 1,2,3 & 7.
Qualified Individuals *
The content of CPD hours must be relevant to each category of retail financial product in which you are accredited. For example, an individual holding the QFA must complete one hour CPD in categories 1, 2, 3, 7 & 8. When all of the ‘one-hour’ and Ethics requirements have been met, the remaining hours (to make up the overall 15 hour requirement) can be made up of other CPD hours, provided they are relevant to any of the five categories.
* ACII qualified individuals – please refer to the following link.
Annual Fitness & Probity Due Diligence
Under the Central Bank’s Fitness & Probity requirements, on an annual basis firms must carry out an audit of persons who hold a PCF( Pre-Approved function) or CF (Controlled Function) role within their brokerage. All persons who act as a PCF or CF should be asked to certify that they are aware of Fitness and Probity Standards and that they agree to continue to abide by those Standards. They are also required to confirm whether they are aware of any material developments in relation to their compliance with the Fitness & Probity Standards since due diligence was last carried out.
All persons holding a PCF/CF must read the Fitness & Probity Standards and complete the required Controlled Function Annual Declaration. This declaration is required to be completed on letterhead and retained on file.
NOTE: There will be a separate requirement to submit an annual PCF declaration on the Central Bank’s online reporting system – this is normally completed in Jan/Feb. Brokers Ireland will update members when this return is available for completion.