Initial Disclosure Documents (IDD) - A Reminder

A gentle reminder, that with effect from 27th March 2017, the Initial Disclosure Document (IDD), that is one of the mechanisms for meeting the FCA’s regulatory disclosure requirements, will be withdrawn in its current form by the regulator and CANNOT be used after that date.

There are several ways in which a regulated insurance broker can meet its disclosure requirements and the IDD is one of them. A Client TOBA is used by many and there are documents that can be used which are similar to the IDD.

So, if you use the IDD in its FCA form, you must replace this by 27th March and a new revised disclosure template is available on the templates support area of the AVIVA Development Zone for RWA Compliance Club members. This looks similar, but has been amended to reflect the new FCA requirements and is somewhat more flexible as you will recall that if you use the IDD currently, you cannot make any amendments to the text as laid down by the regulator, so the new document allows more flexibility.

Please speak to your usual RWA contact if you requite any assistance or have any questions.

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.