III IC-84 cheat sheet
III IC-84 · Keep the key ideas within reach.
Principles and Practice of Insurance
Insurable interest requires a legal or equitable relationship to the subject matter such that loss or damage causes the insured a pecuniary or legal detriment; it must exist at inception for life/person insurance and at the time of loss for property insurance.
Indemnity principle: property and liability cover restores the insured to pre-loss financial position, never profit; life and personal accident policies are valued (benefit) contracts and are exceptions.
Utmost good faith (uberrimae fidei) obliges both parties to disclose material facts; materiality is judged by whether a prudent insurer would be influenced in fixing premium or deciding to accept the risk.
Proximate cause: the dominant, effective, efficient cause producing the loss, not merely the last event; where two perils operate concurrently and one is excluded, outcome depends on whether the loss is divisible.
Subrogation transfers the insured's recovery rights against third parties to the insurer after indemnity is paid; the insurer cannot recover more than it paid and cannot prejudice the insured's uninsured balance.
Contribution applies where two or more policies cover the same interest, peril, and subject matter; each insurer pays rateably or per the policy's independent liability clause.
Utmost good faith disclosure duty is modified by statute in many jurisdictions (e.g., duty of fair presentation), replacing passive disclosure with a duty to make a fair presentation of the risk.
Average clause in underinsurance: claim payment = (sum insured / value at risk) x loss, applied to partial losses only.
Insurance Business Regulation and Compliance
Licensing gate: an insurer, broker, or agent must hold the specific class-of-business authorization before transacting; acting outside authorization is an offence regardless of good faith.
Solvency margin = admissible assets minus liabilities, expressed against a required capital amount (e.g., a prescribed multiple of premium or claims); breach triggers supervisory intervention, not automatic insolvency.
Treating Customers Fairly / conduct outcomes focus on product design, sales, post-sale service, and complaint handling; outcomes are tested, not merely policies documented.
Anti-money-laundering: customer due diligence, beneficial ownership identification, enhanced due diligence for politically exposed persons, and suspicious activity reporting to the financial intelligence unit.
Complaints must be logged, acknowledged, and resolved within prescribed timeframes with escalation to an independent ombudsman or dispute-resolution body.
Sanctions screening is strict-liability in many regimes: a match requires blocking or freezing and reporting, even where the match is later shown to be a false positive, until cleared.
Data protection: personal data must be processed lawfully, minimized, retained no longer than necessary, and subject access requests answered within statutory periods.
Market conduct supervision covers mis-selling, disclosure of remuneration, claims handling timeliness, and outsourced function oversight.
Underwriting and Risk Assessment
Moral hazard relates to the character, honesty, and financial motivation of the insured; morale hazard relates to carelessness or indifference after cover is purchased.
Risk improvement hierarchy: avoid, reduce, transfer, retain; underwriting selects which risks to accept, on what terms, and at what price.
Rating factors must be actuarially justified, statistically credible, and non-discriminatory under law; proxy discrimination through correlated variables is a regulatory risk.
Claims experience rating uses loss ratio = incurred losses / earned premium, adjusted for credibility weighting and trend.
Retention and reinsurance interplay: facultative placement is per-risk; treaty placement is automatic for all risks within defined parameters.
Physical hazard examples include occupancy, construction, protection (sprinklers, alarms), housekeeping, and exposure to neighboring risks.
Aggregate exposure limits cap total accumulation per policy period across all covered locations; reinstatement provisions restore limits after loss, sometimes for additional premium.
Duty of fair presentation requires disclosure of every material circumstance the insured knows or ought to know, plus sufficient information for a prudent insurer to assess the risk.
Claims Management and Loss Assessment
Notification duties: prompt notice, cooperation, and proof of loss are conditions precedent to recovery in many policies; late notice prejudice is a coverage question.
Reservation of rights letter preserves the insurer's defenses while investigation proceeds; it is not a denial and does not waive coverage.
Indemnity measure for property: actual cash value (replacement cost less depreciation) or replacement cost, depending on the policy wording; betterment is excluded.
Business interruption: gross profit basis covers lost turnover less saved costs plus increased cost of working; indemnity period must align with the time to restore turnover.
Salvage and subrogation recoveries reduce net claim cost; salvage disposal requires care to avoid liability for negligence in handling.
Liability claims: investigate liability, quantum, and coverage; settlement within limits requires the insured's consent unless a hammer clause applies.
Fraud indicators: inflated inventories, pre-existing damage, late reporting, refusal to provide records, and inconsistent statements; suspicion must be documented and referred per procedure.
Average, excess, deductible, and policy limits apply in a defined order; the deductible generally applies before the limit and before average where both are present.
Insurance Distribution, Marketing and Customer Service
Disclosure of commission and remuneration is a core conduct requirement; conflicts of interest must be identified, managed, and disclosed to the customer.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require clear warnings and documented customer election.
Product governance: target market definition, distribution strategy, and post-sale product review (value assessment) are required before and during distribution.
Cooling-off rights allow cancellation within a defined period; refund calculation differs for life and non-life products and must be disclosed at point of sale.
Marketing rules: financial promotions must be fair, clear, and not misleading; past performance and guarantees must not be overstated.
Client money handling: premiums collected by intermediaries are held in segregated statutory trust accounts with reconciliation at prescribed intervals.
Complaint handling and customer service metrics: first-contact resolution, complaint root-cause analysis, and turnaround times feed conduct risk reporting.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines the scope of advice and product range offered.
Know Your Customer information (needs, objectives, financial situation) must be recorded before a recommendation is made.
Remuneration models: commission, fee, and fee-offset; disclosure of the basis of payment is required before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; these are conduct indicators regulators review.
Advertising approval processes must ensure claims are substantiated and comparisons are verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and record-keeping of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.
Insurance Distribution, Marketing and Customer Service
Remuneration disclosure: commission, fee, or other benefit must be disclosed in a form the customer can understand before the contract is concluded.
Advice versus information: a personal recommendation requires a suitability assessment; execution-only sales require documented customer election and warnings.
Target market and product governance: products must be designed for an identified target market and distributed accordingly, with post-sale review of value.
Cooling-off rights allow cancellation within a defined period; refund calculation differs by product type and must be disclosed at point of sale.
Financial promotions must be fair, clear, and not misleading; comparisons must be verifiable and past performance not overstated.
Client money: premiums held by intermediaries belong in segregated statutory trust accounts with periodic reconciliation.
Vulnerable customers require adjusted communication, extra time, and documented suitability checks; vulnerability is not limited to age or disability.
Complaint metrics (volume, root cause, resolution time) are conduct risk indicators reviewed by supervisors.
Insurance Distribution, Marketing and Customer Service
Distribution channels: tied agent, independent intermediary, broker, bancassurance, and direct; channel determines scope of advice and product range.
Know Your Customer information (needs, objectives, financial situation) is recorded before any recommendation is made.
Remuneration models: commission, fee, and fee-offset; the basis of payment must be disclosed before the sale completes.
Cross-selling must not override suitability; bundled products require transparency of each component's price and optional nature.
Customer service quality is measured by complaint ratios, claims settlement times, and retention; regulators review these as conduct indicators.
Advertising approval processes must ensure claims are substantiated and comparisons verifiable.
Vulnerability and accessibility: alternative formats, plain-language documentation, and records of adjustments made are expected.
Post-sale review: annual reviews of protection needs and product performance are a distribution duty where ongoing advice is promised.