Updated Terms of Business Template
Thu Sep 27 2018
As a result of the Insurance Distribution Regulations (S.I. 229 of 2018) Brokers Ireland has updated the Terms of Business Template (TOB). Brokers must read this document carefully and delete the sections/wordings not applicable to them. It is not possible for Brokers Ireland to include every scenario within the TOB, so brokers will have to be mindful of that and make amendments as necessary.
Our recent changes are in red, some of which are outlined and explained below:
- There are changes required under the provision of services/products on the basis of fair analysis or limited analysis. The limited analysis is broken down into two sections. The fair analysis is expanded and now called fair and personal analysis. Brokers will have to delete the sections not relevant to them.
- Other changes are under the Statement of Charges, in respect of disclosure of fees/commissions and other forms of remuneration.
- It should be noted that if you are offering insurance based investment products (IBIPs) on an independent basis you must offset against fees to be paid by the customer, any fees, commissions or non-monetary benefits paid or provided by any third party or person acting on behalf of a third party in relation to the services provided to that customer as soon as reasonably possible after receipt, i.e. you cannot describe yourself as independent if you are receiving any other form of commission or payment other than from the customer.
- Please delete reference to the above section within the TOB, if you are offering IBIPS but do not describe yourself as independent in respect of these products.
- Regulated entities are now required to provide a written reply to all complaints received from their customers, not just complaints received in writing. Please note this change in the TOB as attached.
For further information, please email firstname.lastname@example.org