0800 619 6619 info@branko.org.uk

All Matters General Insurance, 27 March 2020

27 Mar 2020 – hosted by the Insurance Institute of London

All Matters General Insurance

  • Key GI initiatives from the FCA – distribution chain value assessment, harm indicators and the Dear CEO letters
  • IDD requirements – compulsory training, marketing materials, conducts of business, product oversight and governance, conflicts of interest, system and controls, PII cover, client money and ancillary insurance intermediaries together with HMT/FCA changes to introducing activity

This event repeats the one on 3 February where delegates commented:- “Very clear with good examples”, “Good knowledge on topic” and “Clear presentation”.

Book here – https://www.iilondon.co.uk/home/cpd-events/lectures/2020/march/fca-focus-on-general-insurance-distribution-chains-value-dear-ceo-letters-and-the-idd/

Non-financial misconduct in General Insurance – are you doing enough? 4 March 2020

4 Mar 2020 – hosted by the Insurance Institute of London

Branko will talk about the FCA’s interest in non-financial conduct and focus especially on their recent Dear CEO letter and suggest what is needed and how what the sector can do collectively will be a win/win for all concerned.

The FCA has a deep interest in general insurance for some time now and has made it clear with various policy statements and changes to rules, that what we do is simply not acceptable. Be it differential pricing, unnecessary and low value distribution chains, the handling of vulnerable customers, and now, overall non-financial conduct and culture issues.

Branko has worked tirelessly as a volunteer for the CII (VP 2008-2014) and his local institute (Luton & Herts since 1991) and strongly believes that demonstrating industry engagement is a strong indicator of good conduct. In addition, he has published the BIBA Compliance Manual since 2004 and has a knack in compressing voluminous FCA rules!

Please book here:- https://www.iilondon.co.uk/home/cpd-events/lectures/2020/march/non-financial-conduct-in-general-insurance-are-you-doing-enough/

Insurance Times: FCA’s pre-existing medical conditions signposting rules: What does it mean for the industry?

Please note that the full interview/article (which will include contributions from others) is available direct from the provider’s site and that copyright applies to the whole article – therefore my contribution only has been quoted.

Branko Bjelobaba, managing director at consultancy Branko Ltd told Insurance Times that it is a ”good initiative from the FCA” as it enables those requiring travel insurance to be confident when buying it that they are getting something that will work.

”The days of the seller simply relying on exclusions with no thought as to how the policy will or won’t work will be long gone as thought has to be given as to whether the insured has pre-existing conditions. However, a professional will never have sold a policy without fully checking that it will cover the person fully.”

Post Magazine: Analysis – rise of the clones

Please note that the full interview/article (which will include contributions from others) is available direct from the provider’s site and that copyright applies to the whole article – therefore my contribution only has been quoted.

From the Post Magazine “Criminals are very good at getting money out of people using little effort.” He added: “This is theft, and potentially dangerous theft as you could be uninsured and risking damage to your car or other people and their cars or property and the costs of the latter will fall onto other law-abiding motorists in terms of their contributions to the MIB uninsured drivers’ fund. “As people don’t really care who they are insured with, anyone can set up online and pretend to be a broker and pretend to place the business and issue invalid documents.” Bjelobaba added: “It’s a very easy fraud to get away with and so hard to discover. The only way to discover it is when you make a claim or a car goes through automatic number-plate-recognition and the police get in touch to say you are not on the Motor Insurers Bureau database.”

There is also speculation that this type of fraud is bolstered by inside knowledge. He said: “You have to gather quote information, produce legitimate looking documents and take payment – all of that requires effort and intelligence and someone who is good on websites. Plus you have the money trail as all payments are electronic. You will need to be listed either on Google or on the comparison sites, so both of those need money and I can’t imagine the latter not doing proper due diligence on ‘brokers’ wanting to be included in the listings.” Clone broking is hard to prevent, said Bjelobaba, as it is “impossible to police until it goes all wrong”. He added: “Then a trail has to happen, which is going to keep the police busy, especially if hived off to their online fraud section, which will be under resourced.”

Insurance Age: Why do brokers need to care about the FCA focus on D&I?

Please note that the full interview/article (which will include contributions from others) is available direct from the provider’s site and that copyright applies to the whole article – therefore my contribution only has been quoted.

And a good starting point in understanding culture is to look to employees.

“Speak to your employees, ask them what it’s like to work here,” compliance consultant Branko Bjelobaba advises.

“As long as the organisation espouses diversity and inclusion, understands what that means and there are no hidden unconscious biases to employing people, there isn’t a problem.”

And for anyone who may think this is something that can be delegated to HR, there is unanimity that this is a serious, leadership-level issue and that the FCA will expect firms to treat it as such.

“This should be a board agenda item, not just box-ticking” says Bjelobaba.

Insurance Times: FCA takes aim at bad broker behaviour

“The FCA must have seen something nasty to come out with this statement,” said compliance consultant Branko Bjelobaba.

New obligations on firms to keep disciplinary reports for as long as six years means that failures to tackle non-financial misconduct will have implications for senior managers’ future prospects, he said: “Individual behaviour is so much more important than it ever has been.”

The FCA identifies lack of diversity and inclusion, together with non-financial misconduct, as obstacles to creating an environment in which it is safe to speak up, with consequences on retaining talent. Bjelobaba agreed with the FCA’s contention that a more professional approach pays off. He said: “The quality of business that emanates from professional insurance brokers is much better.”

The new regime means human resources professionals, traditionally not prominent within insurance broking, will become more important figures, said the senior compliance source, saying: “Compliance officers often now sit on boards. The same may happen with HR.”

Post Magazine: Compliance experts praise outgoing FCA boss Andrew Bailey

Please note that the full interview/article (which will include contributions from others) is available direct from the provider’s site and that copyright applies to the whole article – therefore my contribution only has been quoted.

From the Post Magazine

Branko listed Bailey’s legacy as “steady but sure” and having had a “good reaction to some of the failures in banking”. “There was an inability to pursue the many individuals who will have had blood on their hands…now with SMCR, this is sure to be different.”

And over the costs of regulation:-

Branko questioned the low level of “control over cost and value for regulated firms and very little accountability” at Bailey’s watchdog.

Post Magazine: Brokers urged to keep on top of SMCR as rules kick in

Please note that the full interview/article (which will include contributions from others) is available direct from the provider’s site and that copyright applies to the whole article – therefore my contribution only has been quoted.

From the Post Magazine

“You have to attest to the fitness and proprietary of your staff and evidence it,” he highlighted. A year from now nearly all staff become subject to conduct rules. Anyone behaving in a malicious and deliberate way can be held accountable by the FCA which is brand new, Bjelobaba said. While there is plenty of time for firms to undertake the training a key point is that this cannot be a blanket style approach. When explaining the rules to staff it must be in the context of their particular role in the company, compliance experts stressed. “It is more than box ticking,” Bjelobaba said. “It is taking ownership of conduct and behaviour and instilling in your team that your own personal conduct is on the line. “This is not Mickey Mouse. It is statutory law. If you break this you break the law.”

In his opinion the FCA is employing more people for front line supervision and is ready to catch and “feel the collar” of people not taking it seriously. “It is an enhanced level of trust. This is a transition to an even better state of compliance and culture.”

Insurance Times: FCA responds to staff misdemeanours amid leaked letter storm

Please note that the full interview/article (which will include contributions from others) is available direct from the provider’s site and that copyright applies to the whole article – therefore my contribution only has been quoted.

From the Insurance Times

However, some believe that the FCA should have been “ultra-honest” and sent the letter to the press themselves.

Branko Bjelobaba added: “[The FCA] ask all regulated firms to act with integrity and to be open and honest with them, yet they try and hide their own issues.  I was of the opinion that they only hired staff of the highest calibre – professional, steadfast, leaders, movers and shakers – there to lead the financial services profession, but to have staff poo and wee on the bog floor demands that they clean up their act pronto.”

He told Insurance Times that to have “women knocking back alcohol and then dumping the bottles in the sanitary bins” suggested there are concerning staff issues that are not being dealt with, contradicting the ethos of today’s world of employment.

Post Magazine: Jaw-dropping behaviour at the FCA

Please note that the full interview/article (which will include contributions from others) is available direct from the provider’s site and that copyright applies to the whole article – therefore my contribution only has been quoted.

From the Post Magazine

“Those that lead the financial services industry should uphold good manners. The FCA pays very decent money to its staff and they’ve got a purpose-built building just for them so how all that can happen is really odd. If it’s expecting people in financial services to stand up and be honourable and accountable, then that should start at the FCA.” Branko highlighted the disposal of alcohol bottles in sanitary bins at the regulator’s offices: “Drinking during the day and putting the bottle in a sanitary bin suggests that there is a problem that the FCA should be looking at. Even if it can’t identify the individual, it needs to put out something that says, ‘we’re happy to talk to you.”