Regulation of the insurance sector continues to evolve with changes to Solvency II on the horizon and the FCA’s rules around General Insurance Pricing Practices (‘GIPP’). This is in addition to the PRA and FCA’s work on building operational resilience in the sector, the new consumer duty proposals, work on diversity and inclusion, and climate change.
The FCA GIPP rules set out to address the harm found by the FCA during their GI Pricing Practices Market Study and are set to have a significant impact on the home and motor markets. The aim of GIPP is to improve the way the insurance market functions by protecting vulnerable customers and banning the practice of price walking. The new rules aim to make it simpler for customers to stop automatic renewals and require firms to enhance product governance rules to ensure fair value for all insurance products.
Operational resilience has been high on the regulatory agenda for some time and remains in focus due to significant issues experienced by firms which include IT failures and failings in relation to outsourcing arrangements. The regulators have adopted a coordinated approach in their proposals outlining the detailed requirements on firms to maintain an Operational Resilience framework that has far-reaching implications across the sector. A shared priority of the supervisory authorities is to have a strong regulatory framework promoting the operational resilience of firms.
At Mazars, we provide tailored and comprehensive compliance services to our clients. We understand that every business's compliance needs are unique, so we deliver a bespoke and personal service. Our core aim is to understand what you are trying to achieve and provide efficient and effective solutions.
Case Study one |
Implementation of the FCA’s general insurance pricing practices (UK Branch of a Large International Insurance Company) We supported a UK branch of an international insurer with the implementation of their general insurance pricing practices for home and motor insurance following issues highlighted in their FCA Risk Mitigation Programme. We prepared pricing questionnaires for the insurer to gather information from their Managing General Agents (MGAs) in relation to pricing activities and we worked with them to draft a Pricing Strategy, which our client shared with the FCA. Our work involved developing the firm’s Pricing Governance & Control Framework for their review and approval, and supporting them through implementation and embedding the framework to ensure they could demonstrate to the FCA that appropriate actions had been taken. We were required to analyse and apply the FCA’s expectations from all of its relevant pricing publications as part of this work. |
Case Study two |
Customer outcome review (Large UK Motor Broker) We worked with a leading UK Motor Broker to undertake a business-wide review of performance against the six customer outcomes defined by the FCA that firms should strive to achieve to ensure fair treatment of customers. We assessed governance arrangements and corporate culture across the business to ensure there was an appropriate level of oversight and accountability across customer journeys and outcomes. We were able to draw conclusions as to the suitability of MI produced across the business. We reviewed the product governance arrangements to ensure products and services are appropriate in meeting the needs of customers and that the firm's marketing of products is clear, fair, and not misleading. We provided an assessment of the firm's policies and procedures as to whether these were appropriate for driving fair customer outcomes, aligned to regulatory expectations, and were suitably embedded across the business. We also undertook a deep dive into the firm's complaint handling to identify any potential cause for concern in respect of service standards or product performance. |
The agreement to pause sales of Guaranteed Asset Protection (GAP) insurance for 80% of the market was a big headline in February. It may have come as a shock to some but the FCA’s concerns with GAP insurance are nothing new, dating back to its 2014 Market Study. The FCA pointed to its 2022 value measures data and had given GAP firms a stark warning in September 2023 over fair value.
In the second quarter of 2023, we saw further advancements on the road to Solvency UK. On 22 June, the Government published the draft regulations to reform the Solvency II (SII) regime in the UK. This was quickly followed by the PRA’s Consultation Paper (CP12/23) on 29 June 2023.
In January 2023, HM Treasury published its consultation paper setting out proposals for the introduction of an Insurance Resolution Regime (IRR) for the UK insurance sector.
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