October 30, 2020

Volume X, Number 304


October 29, 2020

Subscribe to Latest Legal News and Analysis

October 28, 2020

Subscribe to Latest Legal News and Analysis

October 27, 2020

Subscribe to Latest Legal News and Analysis

FCA publishes new supervision strategy for Insurance Intermediaries

In a “Dear CEO” letter published on 4 September 2020, the Financial Conduct Authority (FCA) has set out its supervisory strategy for insurance intermediaries in personal and commercial lines, warning of “significant risks of potential harm” within the insurance sector.

What risks have the FCA identified?

 Within the letter, Roma Pearson (Head of Retail General Insurance) sets out the key risks posed to consumers and the market, highlighting in particular the risk of consumers buying “unsuitable or poor value products”, which is being driven by “insufficient or unclear information” and “inappropriate sales tactics”.

Firms are being asked to consider the extent of these risks within their businesses and to assess whether they have strategies in place to help reduce them.

The key drivers of harm which the FCA has identified are:

  • ineffective governance and oversight of business;
  • incentive arrangements that do not support a healthy culture; and
  • business models which provide poor control over sales, renewals and conflicts of interest.

Supervision of these areas will be prioritised, and the letter further details the ways in which the FCA will assess firms on this basis.

Additional external considerations

The FCA also notes the impact of COVID-19, recognising the potential risk of firms collapsing. The letter re-iterates the FCA’s expectation for firms to plan ahead and minimise disruption in that scenario. If firms are concerned about meeting capital requirements, they are expected to contact the FCA.

In addition, the letter suggests that firms consider how the end of the implementation period for Brexit will affect them and their customers, including what action may be necessary to be ready for 1 January 2021.


Brokers should take action to address the risk areas highlighted in the letter. As part of this, firms may wish to review how they have implemented the Senior Managers & Certification Regime.

Beyond implementing robust governance and controls, the FCA expects firms to embed “healthy cultures and behaviours” in order to drive the required change to the market and to prevent harm from occurring.

The letter confirms that the FCA will be proactively monitoring firms, it will engage with firms to help them complete their key priorities, and will act where firms and individuals are not meeting its expectations.

This strategy will run until September 2021, and firms should expect to receive a further communication from the FCA next year with its updated view on the risks posed.

© Copyright 2020 Squire Patton Boggs (US) LLPNational Law Review, Volume X, Number 255



About this Author

Garon Anthony Litigation Attorney Squire Patton Boggs Birmingham, UK

Garon is a partner in the Litigation Practice Group. He advises clients across the full range of commercial dispute issues, including cyber liability/data breach, professional negligence, banking, pensions and insurance.

Garon regularly acts for clients who are subject to investigations or disciplinary proceedings by national and international regulators, including most recently the Financial Conduct Authority, the Financial Reporting Council and the Dubai Financial Services Authority.

Related Services

  • Litigation
  • Data Privacy & Cybersecurity
  • ...
44 121 222 3507
Rose Chaudry, Squire Patton, Commercial Litigation Lawyer, Tortious Contracts Attorney

Rose Chaudry is an associate in the Litigation team with expertise in general commercial litigation. Rose qualified in September 2015 after completing her training contract with the firm.

Rose regularly acts for a diverse client base, including individuals and companies, from SMEs to PLCs. Rose has experience advising on a wide-range of matters of both a contractual and tortious nature, including breach of contract, breach of warranty, debt recovery, professional negligence and insurance.

44 121 222 3146