Background (SYSC)

Since 2009 a single SYSC sourcebook has applied to most firms in the Financial Services sector.

For General Insurance Intermediaries this meant a much longer and more detailed sourcebook than previously as they are now sharing the same handbook text as Investment firms and the like – generally referred to in the text as “Common Platform firms”.

However, much of the new content (added in 2009), although stated in the form of Rules, is subsequently downgraded for Insurance Intermediaries to Guidance only status which the FCA says “should be applied in a proportionate manner, taking into account the nature, scale and complexity of the firm’s business”.

A table summarising the SYSC requirements for Insurance Intermediaries including whether they should be treated as rules or guidance is included in the template section at the end of this chapter (SYSC Template 13).

The Insurance Distribution Directive (IDD) effective 1st October 2018 resulted in further changes to the SYSC sourcebook including:

• Significant strengthening of the Conflicts of Interests requirements and upgrading previous Guidance to Rules for all firms.
• Introducing a new Remuneration rule to ensure that remuneration arrangements do not conflict with a firm’s duty to act in a customer’s best interests.
• Significant expansion of the “Competent Employees Rule” including a new minimum CPD requirement.
• Moving “Good Repute” requirements from the previous MIPRU sourcebook to SYSC and requiring firms to “ensure” rather than “establish on reasonable grounds” that relevant staff are of good repute.

The Senior Managers and Certification Regime (SMCR), effective from 9th December
2019 for Insurance Intermediaries, introduced new Rules and Guidance some of which
were added to the SYSC Sourcebook, but many others are in other Sourcebooks
including Code of Conduct (COCON) and Supervision (SUP).
In the Special Topics section of this manual there is an overview of the full SMCR regime.
In this SYSC section of the manual those sections added to SYSC as a result of SMCR
are covered in detail at the end of Section A. These cover:
- Classification of SMCR firms;
- Allocation of Prescribed Responsibilities;
- Certification Regime;
- Regulatory References.
This section of the BIBA manual comprises:

Section A – Details of the SYSC Rules and Guidance together with BIBA manual
guidance on how these can be addressed.
Section B – Special Topics. More detailed guidance on the following topics:
 Financial Crime;
 Money Laundering;
 Information Security;
 Anti-Bribery and Corruption;
 Financial Sanctions;
 Business Strategy/Plan;
 Management Information.