Risk and Compliance

28th April 2020

Covid-19, time for reflection

First of all we hope you are all safe.

We appreciate that ongoing world events are the key focus for everyone at present, that said we did just want to send you a short message following the FCA’s recent publication relating to Covid-19.

Two elements I took away from this are:


We are all in ‘not normal’ times and some elements which would not be standard practice will be adopted for these challenging times.

Flexibility is a critical element and - as I type this sitting in my front room adapting to this new way of working - I understand that most will have to adapt in some way.

Our customers will have to do adapt too and we, as brokers, have a vital role in ensuring that customers stay protected and have the benefit of their insurance, as required.

We must ensure that vulnerable customers are given even more assistance and ‘think outside of the box’ as much as possible. 

A simple item such as printing for example; we all print, but working from home and security considerations have put this in a different light, we don’t need to print as much as we thought and signing contracts can be done by electronic signature. 

We should remember the FCA TCF Outcomes and perhaps Outcome 6 is key for this time. As a reminder, this is about our policyholders not having unreasonable barriers imposed on them by brokers or insurers, from pre to post sale.

One area that should be considered is renewals, which are important to all brokers and if you have not done so already, you should give some consideration as to how this will work in the current climate (eg do you have customers that do it by post, do they pay by cheque, do you normally do this in person – none of which may be possible at this time).

The common theme during recent discussions with other compliance people at brokers is if in doubt go back to the FCA 11 Principles - if the activity does not go against a client, then your actions should be fine (for example, P1 states “operate your business with integrity”).

2.Management (leadership)

Following on from the SM&CR implementation last year and the further work required for 2020, regulated firms’ SMFs will be key to ensuring your firm gets through this challenging time.

I am sure none of us thought we would need to put our Business Continuity Plans into practice, but now that we are, we can  review the good and bad points in order to improve our plans for the future.

As required by the SM&CR, your firm’s SMFs should have a Statement of Responsibility (SoR) in place that indicates who is responsible for the key task of BCP; this simple document allows the regulator to see, if required, who has responsibility for business continuity.

Although we currently have until December 2020 to fully implement all SM&CR required items, I think these times will highlight the true role of the SMFs at a regulated firm (the leadership) and also the Certified Person population as the next level down.

Myself and my partner, along with our family, are currently safe and indoors and like everyone else we are just getting on with it as best we can and watching many more films!

Our thoughts go to those people affected by the virus all over the world and especially for those UK citizens who are stranded abroad who hopefully can return soon safely.

Please do visit the FCA website and read their Covid-19 update relating to expectations of brokers and insurers (section: Insurance and Coronavirus (Covid-19): our expectations of firms).

Stay safe 



Barry Holmes Dip(Comp) MICA, Spec.Cert(Sanctions), Spec.Cert(CorpGov), Spec.Cert(Conduct), Cert.(FinCrime),  Cert.(Comp), Cert.(AML), AwSRE, Spec.Cert(AML- PrivBanking), AwCCH MLIBF, UKFR,  Cert.(KYC/CDD), Cert.(CFT), Spec.Cert(ABC) 

Head of Risk & Compliance
Iris Insurance Brokers Limited
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