This bumper edition of the Intermediary Times focuses on the key supervisory and regulatory issues that affected insurance intermediaries in 2018. The newsletter includes articles on:
Brexit contingency planning; the Intermediaries Road Show; the 2018 Central Bank funding levy; findings from the Central Bank's thematic inspections regarding Managing General Agents and the Sale of Gadget Insurance; CPD requirements under the Minimum Competency Code for grandfathering applicants; and observations from recent Anti-Money Laundering (AML) inspections.
Following feedback received by the Central Bank on the industry funding level, the Central Bank has made some amendments to the Intermediary Funding Model. All firms are now required to pay the minimum levy of €1,020. Firms whose fee and commission income exceeded €200,000 in 2018 are also required to pay an additional variable levy rate of 0.32% of their income.
Observations from recent AML inspections included insufficient evidence that staff in senior roles were appropriately trained and that training records maintained by firms were inadequate.
The Central Bank also reminds firms in the process of transferring or ceasing their regulated operations of their obligations under rule 3.11 of the Consumer Protection Code 2012 regarding the notification/treatment of customers in such circumstances and notification to the Central Bank. Notifications under rule 3.11 can be made to the Central Bank at email@example.com. Following a review of the notification the Central Bank will follow-up with firms before the transfer is complete. Those firms seeking to cease operating can do so by submitting a completed revocation form to firstname.lastname@example.org.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.