www.compliancy-services.co.uk @compliancysrvcs cho training support iain stephen jt. ceo compliancy...
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www.compliancy-services.co.uk@compliancysrvcs
CHO Training Support
Iain StephenJt. CEO
Compliancy Services Ltd.
Compliancy Services & The CHO
A long association since NACHO
Associate members since 2006
Member of the CHO Executive Committee
Support members/clients
- Authorisation - Ongoing retainer services - Training & Competence commitments - Audits and Monitoring strategies - Treating Customers Fairly (TCF) - Online e-learning modules & assessments
Offering expertise to entire membership
Credit Hire Industry under pressure from insurers
Promote united, consistent & professional service offering
Insurers want Credit Hire market regulated (obliterated!!!!)
CHO membership is currently subject to regulation
- c.80% of CHO members are either FCA authorised / MoJ regulated
- c.50% GTA members
FCA Regulated activity can only be performed if
Firm is directly authorised by the FCA
Firm is an Appointed Representative of a Principal firm directly authorised
- May only perform activities for which principal has permissions
Exempt firms
Professional bodies (e.g. Solicitors – SRA regulated)
FCA Regulated general insurance activities
The regulated general insurance activities (fully explained in Part 2 of FSMA):
Advising customers on non-investment insurance contracts
Arranging (bringing about) deals in non-investment insurance
Making arrangements with a view to transactions in non-investment insurance contracts
Dealing as an agent in non-investment insurance contracts
Assisting in the administration and performance of a non-investment insurance contract
Agreeing to carry out a regulated activity
Credit Hire firms activities caught by FCA regulation when doing
FNOL (first notification of loss)
- referred non-fault accident victim when notification to TPI of imminent claim
Advising/arranging general insurance contracts
- LEI policies - Insurance policies to mitigate failure to collect vehicle rentals from TPI
Handling claims against TPI on behalf of customers
- maintaining and managing the chronology of claims
Ministry of Justice
The Claims regulator: Kevin Roussell (a unit of the MoJ)
Run by Staffordshire County Council and regulates
Personal injury Claims Mis-sold financial services products/services
Employment / Redundancy claims
Criminal Injury claims
Industrial Injuries
Housing disrepair
Role of the Claims regulator
Licensing firms and individuals to provide claims management services
Take action against firms breaching regulations
Carry out regulatory and criminal investigations
Provide guidance and advice to consumers, organisations and regulated firms
Lead policy reforms for claims management regulatory system
Increasing consumers awareness of charges firms can make
Dealing with unauthorised firms offering claims management services
Basic principles of regulation
GOVERNANCE
CULTURE
CONTROL
What does regulation entail
FCA
Documented compliance manual Compliance monitoring programme Risk Assessment policy Governance policy Financial promotions policy Breach logs, procedures and classification of breaches Business Continuity/Disaster recovery plan Complaints procedure Training and competence strategy and documented scheme TCF policy / procedures and monitoring scheme Data Security / ICO registration Remuneration scheme
What does regulation entail
Claims Management Regulation
Complaints procedures
Data protection / ICO registration
Compliance Monitoring Programme
Introducer Registration form
Introducer monitoring sheets - (less than 25 paid referrals per quarter) or authorisation
Exempt Introducer’s register - reason for exemption
Remuneration scheme
CHO Training programme 2016 – available to members only
CHO Code of Conduct
Assisting Customers with Claims
Complaints
Approved Persons
Basic Insurance Principles
Compliance Monitoring
Data Protection
Health & Safety
Bribery & Corruption
Credit Hire Customer Support Knowledge
Supervision
FCA Regulatory Environment
Treating Customers Fairly
MoJ Compliance Monitoring
Additional insurer issues (e.g.) - rate evidence - rebuttal statements - pitfalls - impecuniosity - intervention
Login
Available Courses
The Company Dashboard
Training requests
Training available at subsidised rate for members only; - online via the CHO training platform, or - classroom in house if subject demands it
All requests for specific training subjects please contact Martin Andrews on
07730 517 699 or email [email protected]
A few compliance reminders
All customer service numbers should now be at standard rate (CRD)
Consumer Credit Interim permission slots last 3 months (FCA) or lost
Calculation of Credit Broking regulated income - if no direct commission then 5% + 0.5% of resulting loans
Complaints handling changes - no initial 4 week response and then 8 weeks final - changes again in 2016 immediate reference to FOS after final response
Connect system for all changes to firms status
General Insurance add ons: thematic review
Accessible to all CHO membersCompliance advice
AuthorisationAudits
Monitoring programmesTraining
Iain Stephen Office 01462 512020
Mobile 07885 962781
Email: [email protected]