In preparation for the Insurance Distribution Directive (IDD), the FCA has listed eight key criteria with regards to your T&C obligations. It is certainly not an exhaustive list, but it will be the responsibility of each firm to ensure staff are adequately trained on their associated in-house policies and procedures, along with legislative or regulatory requirements.
The directive affects all those who sell, advise or transact in insurance. It also extends to those who administer or perform contracts relating to insurance.
To assist you, the Aviva Development Zone team at RWA e-Learning (in conjunction with our in-house compliance specialists) have considered what courses you will require. The relevant areas are as follows:
Policy Terms and Conditions - In relation to the insurance you sell and the associated wordings. The Development Zone can house your own in-house product training in the custom-content area of the system so it may be good to explore this option. The onus will be on the firm to ensure their training covers all bases in this regard.
Applicable Law (i.e. insurance law) - Courses within the Development Zone include: 'Basic English Law', 'Induction Course 1.1 The Law', 'Induction Course 1.3 Codes of Conduct and Behaviour', 'Insurance Act Guide', and 'CIDRA'.
Claims - The 'FCA Regulation Claims' course provides a comprehensive overview, and there are additional within the library courses relating to specific classes of insurance. To assist further, you can place in-house claims procedure and policy documents in the custom content area of Development Zone
Complaints – The 'FCA Regulation Complaints' course delivers a well-rounded summary of the subject. Furthermore, the custom content section of the platform can be used to store and communicate your complaints policy to all staff, and monitor access to ensure that it has been read.
Assessing Customer Need – The Development Zone courses: 'FCA regulations TCF', 'Understanding Customer Needs' and 'Vulnerable Customer Pathway' will be beneficial to you here. Also, consider your customer base and product range - what bespoke content could you need via custom content, which would be useful for your staff?
Business Ethical Standards - Course titles: 'Introduction to Business Ethics', 'Anti Bribery and Corruption' - plus a host of soft skill courses assisting you in best practice business skills - great for supporting a healthy organisational culture
The Insurance Market - Please refer to the course title: 'Insurance Broking in the Insurance Market'. It is also worth considering how changes in the market are communicated to staff via the custom content section (i.e. by uploading links to articles, in-house newsletters etc.).
Financial Competency - The FCA has not been prescriptive here, but it needs to be relevant to the role undertaken. Development Zone courses such as: 'Money Laundering', 'Basic Business Finance Pathway', 'Client Money' and 'Consumer Credit' will assist. Also, it would be worth reviewing Premium Finance training materials too.
The Development Zone will allow you to assess your staff knowledge and competency on a wide range of topics, in addition to those detailed above.
There will also be items that only you as a firm can determine, as they will be very specific to your operation.
To assist with firm-specific training; the Custom Content area of the Development Zone allows you to decide what documents are crucial for your staff to learn from, or to reference. By centrally placing these documents in each staff members T&C, you can be assured that communications are not simply reliant on hoping they read emails!
Any custom courses that you upload will also benefit from the same assessment functionality, allowing you to define staff achievements and training gaps accurately.
If you or your firm are not registered on the Aviva Development Zone, please email firstname.lastname@example.org.
As always, our team are here to help. Please get in touch if you want any further assistance. We are with you all the way,