September will be a busy month: We understand the FSB will be keeping us all busy this coming month with a series of draft regulatory changes. These are expected to include;
- Some provision to allow Juristic Representatives to collect premiums into their own bank account.
- Exempting a UMA from the need for PI.
FSP’s collecting premiums will no longer need a 19(3) audit nor be subject to the liquid asset requirement.
All of the above are likely to be subject to insurer approval/mandate and their ultimate responsibility.
The UMA one in particular once again will force a closer relationship between the UMA and insurer.
- Amendment to the FAIS advertising standards and complaints management. We expect this is to align with TCF standards. We have been promoting for some time the need to upgrade complaint procedures and recording to align with TCF standards so it is likely our suggestions will now become a requirement.
- Draft 2 of the Fit & Proper amendments (originally published in December 2015) We expect that these will now include the CPD standards along with the product training requirements as the two will inevitably be closely aligned in practice. They may also include the competency requirements for the proposed RDR driven intermediary structures which we further understand will deal with the regulators plans for dealing with people who should be appointed as representatives within the travel agency sector.
- An updated Twin Peaks road map. Hopefully this will give us all some meaningful time lines on the various aspects of this project to assist with planning by all affected parties.
As and when we get the actual detail we will obviously communicate further.