PSC Insurance Group Ltd
PSC Insurance (Europe) Ltd - Compliance & Procedure Manual
Table of Contents
PSC Insurance Group Ltd
PSC Insurance (Europe) Ltd - Compliance & Procedure Manual
Section 1 – Introduction
Section 2 – Code of Conduct
General Principles
Section 3 – Definitions
Account Executive
Advertisment
Agent
ATLAS
BAR
Binder
Binding Authority
BIPAR
Carrolls
CBI
Checklists
Client
Client Monies
Complaint
Consumer
Consumer Protection Code
Contract Certainty
Coverholder
Direct Insured
Director
Distributor
ECF
EEA
Employee
FCA
File Checklist
Insurance Product Information Document
Insured
Insurer
IPID
Lineslip
Lloyd’s
Major Subjectivity
Manufacturer
Market Reform Contract
Online Platform
Paragon
Personnel
PSCE
PSCEUK
Producer
Reinsured
Short Rate
Slip
Third Party
TOBA
Underwriting Agents
Websure
WIBAL
Section 4 – Procedures
4.1 Generating Business – Contacting consumers
Personal Visits
Telephone Contact
Personal Visits and Telephone Contact
Communication by Electronic Media
Advertising
Website
4.2 Terms of Business
4.3 Knowing the consumer (Factfind)
4.4 Assessing Suitability
4.5 Statement of Suitability
4.6 Client Premium Handling (Handling Procedures)
4.7 Rebates
4.8 Complaints
4.9 Errors Handling
4.10 Competency and Training Procedures
4.10.2 Ongoing Supervision
4.10.1 Initial Training Goals
4.10.3 Continuous Professional Development (CPD)
4.10.4 Definitions
4.10.5 Streamlining a competent workforce
4.10.6 Anti-Money Laundering-Annual Refresher Training
4.11 Conflicts of Interest
4.12 Business Referrals
4.13 Distance Marketing
Distance Communication
Restrictions on use of distance communication techniques
4.14 Passporting under the Insurance Distribution Directive
4.14.1 Notification Procedure
4.14.2 Brexit
4.15 Accounting Procedures and Submission of On-line Accounts
4.16 Product Oversight and Governance
4.16.1 Manufacturers of Insurance Products
Product Approval Process
Target Market
Product Testing
Product Monitoring and Review
Distribution Channels
Documentation
4.16.2 Distributor of Insurance Products
Informing the Manufacturer of Issues
4.6.2 Documentation.
4.17 Bundling and Contingency Selling
4.18 Commission Disclosure Document
Section 5 – The Sales Process
5.1 Introduction
5.2 Sales Process in Brief
Prospecting
First Point of Contact
Know Your Client
Product Research
Assessing Suitability
Statement of Suitability
Anti-Money Laundering
Before signing the Proposal
Post-Sale
Research Fair and Personal Analysis
Limited Analysis
Receipts
5.3 Enhancing the Sales Process
5.4 Vulnerable Customers
OLD
Section 3 – General
Regulatory Summary
PSC Insurance (Europe) Limited
PSCE Organisational Chart
Worldwide Insurance Brokers & Advisors Limited
WIBAL Organisational Chart
Market Participants
BIPAR Asbl
Brokers Ireland
Central Bank of Ireland (CBI)
Companies Registration Office (CRO)
Data Protection Commission
European Insurance and Occupational Pensions Authority (EIOPA)
Financial Conduct Authority
Financial Services and Pensions Ombudsman (FSPO)
Section 4 – Placing
4.1 Slips & Quotes
4.2 Contract Certainty
4.3 Slip Format
4.4 Overseas Markets
4.5 Permitted Classes of Insurance and Countries
4.6 Quoting Terms
4.7 Incoming and Outgoing Emails
4.8 Approved Insurers/Licensed Insurers
Insurance Product Information Document (IPID)
4.10 Treating Customers Fairly, Independent Advice, PSC’s Remuneration
4.11 Limited Markets
4.12 BIPAR
Subjectivities
A. Deadlines
B. Consequences
C. Claims
4.14 Filing placing documents
4.15 Mid-Term Appointments/Broker of Record Letters
4.16 Firm Orders, Binding Cover and Back Dating
4.17 Premium Warranties
4.18 Verbal Agreements
4.19 Placing Files & Policy Documentation
4.20 Binding Authorities and Conflicts
4.21 Holding Covered
Premium and Claims Data
Section 5 – Technical
5.1 Cover Notes/binders
5.2 Debit Notes
5.3 Excess placements and excess wordings
5.4 Commission/ Brokerage/ Fees
5.5 Grossing Up of Premium
5.6 Allegations of Negligence
5.7 Funding of premiums and claims
5.8 Requests for extensions of cover and other amendments to policies
5.9 General Underwriting Agreements/Leading Underwriters Clauses
5.10 Reinsurance
5.11 Binding Authorities
5.12 Online Platforms
Section 6 – Compliance
6.1 Approving and contracting with direct clients
6.2 Approving and contracting with Agents/Producers
6.3 Filing of Placing Files, Slips and other Supporting Documents
6.4 Archiving of Placing & Claims Files, Slips and other Supporting Documents
6.5 Renewals
6.6 Security of Insurers
6.7 Unrated Insurers
6.8 Underwriting Agents, Managing General Agents and Brokers with Binding Authorities/Facilities and Lloyd’s Service Companies
6.9 Telephone Calls and Meetings and Broking
6.10 CBI Rules
6.11 Money Laundering
6.12 Fraud, Dishonesty and Bribery
Complaints
6.14 Individual Diary Systems
6.15 TOBA’s with Insurers
6.16 Introducing Clients to other brokers
6.17 Confidentiality Agreements
6.18 Conflicts of Interest
6.19 Transfer of Business
6.20 Sub-Broking
6.21 Third Parties
6.22 Payments of fees to Paragon
6.23 Short Rate v Pro Rata
6.24 Advertising
6.25 Absence from work
6.26 Changing/Amending non Paragon Documents
6.27 Cancelling Policies or Certificates
6.28 Coverholder Audit
Power of Attorney
Personal Visit
Telephone Contact
Existing Customers
Prospects
Section 7 – UK Branch
Section 8 – Appendices
Appendix 1 – Titles & Personnel
A1.1 Board of Directors
A1.2 Chief Executive Officer
A1.3 Head of Compliance
A1.4 Head of Finance
A1.5 Money Laundering Reporting Officer
A1.6 Very Senior Personnel
A1.7 Lloyd’s Devolved Administrator
A1.8 Appointed Person for Archiving
Appendix 2 – Permitted Classes of Insurance
Appendix 3 – Permitted Territories
Appendix 4 – Contract Certainty
Appendix 5 – Authorisations
Appendix 6 – New & Renewing Facility Approval Form
Appendix 7 – BIPAR Principles
Appendix 8 – Confidentiality Agreements
Appendix 9 – New Business Relationship Applications
Appendix 10 – Whistleblowing Complaint Form
Appendix 11 – IPID Templates
Section 9 – Claims
Section 10 – Workflows
Section 11 – Corporate Policies
Anti-Bribery & Corruption Policy
Anti-Money Laundering Policy
Complaints Policy (& Procedure)
Conflicts of Interest Policy
Data Protection Policy
Know Your Client Policy
Sanctions Policy
Training Policy
Treating Customers Fairly Policy
Vulnerable Consumer Policy
Whistleblowing Policy (& Procedure)
Section 12 – Appendices
Titles & Personnel
Insurance Product Information Document (IPID)
Terms of Business Agreement (TOBA)
Download as PDF
A1.7 Lloyd’s Devolved Administrator
Graham Gibbs / graham.gibbs@pscinsurance.ie
Glen Obermaier / gobermaier@paragonbrokers.com
Gary Davis / gary.davis@carrolls.co.uk
Nav Garcha / nav.garcha@pscinsurance.co.uk
A1.6 Very Senior Personnel
A1.8 Appointed Person for Archiving
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