New Part 4A P2P Permissions

Many, if not all of you, will have received an email from the FCA advising that you have been given new permissions to advise on Peer to Peer (P2P) investments.

These are generally not activities in which a general insurance broker would involve themselves (unless there is also an IFA arm within the same regulated firm).
 
We would ask all firms to read the FCA email carefully and if you have not seen it, please check your Spam or Junk folders in case it has been redirected there.
 
If you still cannot find it, please immediately check your Financial Services Register entry and you will see the new permission detailed under the firm name in the coloured box headed “Status: Authorised” and it will say -

Advising on P2P Agreements

This form also has permission to advise on P2P agreements. permissions to carry on this regulated acitivity is subject to the same requirements and limitations as apply to the firm's permission to advise on investments.

The FCA has given this permission en bloc and if you do not envisage needing it then you have to apply to have it removed.
 
There is a simple form to complete, the link to which can be found in the final paragraph of the FCA notice, under the heading “Removing the P2P advice activity”  if the insurance broker wishes to remove these permissions .The form can be accessed here.
 
Please note that you only have to do nothing if you want to retain these new permissions.
 
If you take no action the FCA will assume that you want them and the impact will be greater scrutiny, an increase in your fees and an increased capital adequacy requirement.
 
It is therefore vital that you review and take action immediately if you do not want them. Inaction will have an effect on your firm.

About the author

Terence has over 35 years' experience in the Financial Services environment, covering general insurance, investments and mortgages. Before joining RWA, Terence worked for a large PLC insurance brokerage in Manchester, overseeing some 20 acquisitions. He served as Compliance Director at RWA from 2011 to 2018 and has worked with insurance broking firms of all sizes across the UK. He has a particular interest in Financial Crime and the protecting the insurance broker. Terence previously served as Executive Chairman of the Association of Professional Compliance Consultants (APCC), the professional body for the compliance consultancy sector. He retired from RWA in 2019.

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