Insurance in Financial Services UK
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Regulators are placing increasing emphasis on the management of conduct risk within financial services firms. Central to this is the right management information (MI). The importance of MI is also set to increase in the UK under the Senior Managers Regime (SMR) and Senior Insurance Managers Regime (SIMR), where strong conduct risk MI will help Senior Managers to demonstrate that they have taken reasonable steps to understand conduct risks and that they have put in place appropriate controls.
This is the final part of a four-part blog series on the FCA’s Coverholder and TPA thematic review (often referred to by the FCA as its “distribution chain” thematic review).
Firms are achieving workable conduct solutions for delegated authorities in a number of ways, whether it’s by updating existing controls to add a conduct lens; increasing the evidence and documentation around existing practices; or by designing new aspects of control and oversight.
Automation will change the character of London businesses | How will Financial Services adapt to the new environment?
Since the Industrial Revolution, technological advances have transformed business and commerce, and changed the character of jobs that people do. With the rapid progress of digitisation, a further period of major transformation is under way. London, its Financial Services industry included, will inevitably feel the change and will need to respond.
There has been a fundamental shift in regulatory expectation and good market practice for delegated authority control and oversight frameworks.
This shift may increase cost in key control functions reinforcing the importance of a robust conduct risk assessment (as discussed in our previous blog) to achieve a proportionate and risk-based control and oversight framework. The risk assessment shows you the higher gross risk areas of your business and why they are high risk, enabling you to direct your resource – whether it be delegated underwriting management, compliance, claims or underwriting resource - so that you get more bang for your buck.
This is the second of a four-part blog series on the FCA’s Coverholder and TPA thematic review (often referred to by the FCA as its “distribution chain” thematic review)
The diversity and complexity of Coverholder and TPA populations is a challenge when mitigating conduct risk. A risk-based and proportionate solution is fundamental, so starting with a conduct risk assessment is sensible to provide structure and identify the different exposures to conduct risk.
As we near the outcome of the Financial Conduct Authority’s Coverholder thematic review, general insurance firms across the Lloyd’s and London market should consider how they stack up against regulatory expectations and current good market practice. Over the next month, we will be producing a series of short blogs covering some of the key elements of delegated authority control and oversight that we see the market currently designing and implementing:
Blog 1: Conduct risk assessments
Blog 2: Due diligence, audits and Management Information (MI)
Blog 3: Key market solutions and commercial challenges
The PRA and FCA have published a joint consultation paper (CP) on a series of measures to formalise whistleblowing procedures in firms. The aim is to encourage employees to raise concerns and protect whistleblowers from victimisation. This initiative responds to the Parliamentary Commission on Banking Standards’ recommendation to put in place effective mechanisms to allow employees to raise concerns internally.
UK regulators refine the scope of the Senior Managers Regime and clarify how the ‘Presumption of Responsibility’ will be applied
The Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) have confirmed how the new Senior Managers Regime (SMR) and Senior Insurance Managers Regime (SIMR) will apply to Non-Executive Directors (NEDs) in banks and insurers respectively. This follows the responses received to the Consultation on Strengthening accountability in banking: a new regulatory framework for individuals –CP14/14 published in July 2014, which expressed concern about the proposed approach to NEDs under the SMR.
This is the final entry in our series of three blogs which cover the topic of third party risk. In this article, we explore the design and implementation of frameworks which organisations are implementing in order to help them manage the third party risk. We highlight some of the stages and challenges of creating such a framework and the requirement to make it specific to your organisation in order for it to be successful.