Is the writing on the Caravan wall?
In the latter part of 2021 the FCA issued their widely anticipated consultation paper - Improving the Appointed Representatives Regime (AR) - aimed at improving the Appointed Representative Sector.
Previous thematic reviews had identified significant shortcomings in a Principal’s understanding of their regulatory responsibilities for their AR’s. This often resulted in insufficient due diligence before appointing an AR and poor ongoing control and oversight.
Currently Principals only provide the FCA with high-level information on their AR’s and the market in which they operate. New proposals shown below would provide the FCA with additional information allowing them to identify potential risks within both the Principal and the AR, address potential harm and ensure that the appropriate oversight arrangements were in place.
- Principal to explain the primary reason for the appointment of the AR.
- Provide information on the nature of the regulated activities the Principal permits the AR to undertake.
- Describe any non-regulated activities the AR undertakes. This includes the nature of the non-regulated business, and its size and scale.
- Indicate whether the AR will provide services to retail clients.
- Indicate whether the AR was previously an AR of a different Principal, and if so, why the AR is now intending to operate under a new Principal.
- Whether the AR is part of a group and if so, provide the name to the parent undertaking.
- Whether any individuals from the AR will be seconded or contracted to the Principal firm to carry on portfolio management and / or dealing activities, and if so explain the rationale for entering into such an arrangement.
One sector that this is bound to have an effect on is the sale of Static Caravan insurance, where for many years Caravan Parks have facilitated the sale of insurance to customers, often including providing quotations, collecting premiums and issuing policy documentation. Given the sheer number of ARs involved it has always been difficult to ascertain whether the appropriate level of due diligence and oversight has been in force. This uncertainty has already resulted in some Insurers moving away from AR models to dealing direct. The FCA’s new proposals could be the writing on the caravan wall for those that remain to do likewise.
As the attraction of the AR model in the sector diminishes this provides Brokers with a great opportunity. Whilst customers have an increasing possibility of buying their Static Caravan insurance online, nobody is better placed to provide a solution than Insurance Brokers, who know their customers' requirements better than anyone.
For Brokers wishing to find out more about Static Caravan insurance and the opportunity this presents to introduce a new income stream to their business why not contact Jackson Lee Underwriting to find out more? Our Static Caravan insurance provides a wide range of cover at a competitive price, access to a Senior Underwriter with over 25 years market experience for referrals, administration using our secure online ABEL platform and regular training.