The ‘F’ word

No, not that F word……… I’m talking about fair!

Every insurance broking firm must be able to evidence that the fair treatment of customers is at the very centre of their business model. This can only be achieved by ensuring that your staff have had the correct training and are competent to advise on products offered to your clients.  Therefore, it is paramount that you have an effective T&C scheme in place.

If you don’t already have one, then now is the time to action this. The FCA don’t expect this to be done overnight but they do expect you to have taken steps to put one in place. Although this may seem overwhelming, putting together a T&C Scheme for your firm needn’t be a headache and RWA can assist you with this.

So, why is this important?

Well, with the Insurance Distribution Directive coming into force and from the 8 key competencies outlined by the FCA, a minimum of 15 hours CPD applies to employees who are either:

  • directly involved in carrying out the firm’s insurance distribution activities;
  • those responsible for supervising these individuals;
  • those within a management function with responsibilities around the firm’s distribution activities.

This requirement falls into your T&C Scheme.

You will need to show who has completed their CPD, in what areas and if they are competent.

Another big change this year will come in the form of the introduction of the Senior Managers & Certification Regime (SM&CR).

This regime will not only set out the regulation of all senior staff within your firm but will also have rules that need to be followed by almost all other staff too. These responsibilities for senior staff are significant and the compliance structure for firms will require a great deal of effort, will need FCA approval, a statement of responsibilities and a strong ethical focus (this list is not exhaustive).

Compliance with the SM&CR is the responsibility of the senior management of the firm both collectively and individually, and failure to comply could lead to personal censure including very large fines!

Although all of this may seem like yet another hill to climb to achieve your regulatory obligations, by putting a strong T&C Scheme in place you can only add value to your business.

The outcome will be that your staff will:

  • feel more valued,
  • know and understand what they are meant to be doing, and,
  • maintain competence.

A robust T&C scheme will make sure that you don’t fall behind your competitors and most importantly, will show the FCA that treating your customers in a fair and compliant manner is taken seriously within your firm.

If you are struggling to get to grips with the new regulations, then fear not as RWA is here to help.

The most important thing to remember here is that compliance can be achieved if you have a solid T&C scheme in place to assess, record and regularly re-assess the competency of your staff.

Should you have any questions arising from this article, please contact RWA on 01604 709 509 or email

About the author

Before joining RWA Nicola was a recruitment professional holding posts such as Senior Recruitment Consultant, Senior Account Manager and Senior Business Development Consultant.

Nicola joined the RWA team as Business Development Manager covering all areas of the business before moving into the role of IDD / T&C Scheme Specialist.

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