REGULATION
sets out the main thrust of counter this by the fact that take the time and trouble to being looked at in the current
how they manage their staff all brokers’ staff undergo explain and show them what time and I think some of areas
training, resources and main some form of training almost to do – this is training! What noted, albeit briefly,
methods employed. This every day. about trade press, insurer demonstrate that there is a lot
should also encompass Remember, training is not visits or newsletters? more to this than just looking
recruitment, induction, just about somebody sat in a So, there is a lot more at a rule and seeing how your
supervision and appraisals or classroom watching somebody training out there than meets business deals with it. There
ongoing monitoring. It needs standing at the front, the eye. The trick is having are too many variables.
to demonstrate that regular lecturing them, nor is it just processes in place to If the FSA decides to visit
checks on staff competency about study for professional recognise people’s training you, your approach to
are undertaken, having qualifications. Think about all needs, respond to them and
compliance in these areas is
established appropriate the things that go on in your document what is done –
going to be looked at very
benchmarks. office on a daily basis. How Continuous Professional
closely and you need to have a
Many brokers often many times do your staff ask a Development (CPD). So you all
suite of documents in place to
comment to me that it is very question about a difficult or train, but how many have a
demonstrate not just what you
difficult to evidence training complex commercial renewal, fully documented process to
do but how you do it. It is
as they get little opportunity or come across a risk they demonstrate what is going on?
important to ensure that what
to undertake this. I would have not seen before? You The same can be said for
is in place actually reflects
many other issues, TCF for
what is relevant to your firm
example. If I had a pound (or
rather than just having a set
even a penny) for every time I
of templates with your name
hear somebody say – of course
on it.
we treat our customers fairly,
When I talk to clients
otherwise we wouldn’t have
about these issues we work
any...I have no doubt that
together from a set of
brokers are sincere when they
templates, but the aim has to
say this, but can it be proven?
be to use these as ‘skeletons’
and put on the ‘meat’ which
I
s there a documented
reflects what the broker wants
policy which sets out how
to achieve. We have produced
they achieve this, is there
suites of documents to
appropriate management
manage each of the issues.
information in place and is it
However we do not want to
used? Just as importantly, are
just offer these up to a client,
staff aware of what is
as this does not help.
expected of them? There is no
“one size fits all” approach
here. It is not a set of rules
but guiding principles and it is
up to each firm to find its own
A
good compliance
consultancy will ensure
that the broker
level. There is no point at all
understands the relevance of
in having a two hundred page
the procedure to his business
policy on TCF for a small local
and adopts them in a way that
firm employing two staff. It
works. This is why I see it as
might be all right for a large
vital to sit with a client to
national, but you have to be
build his own compliance
pragmatic and look at not only
regime with the assistance of
your processes but your clients
supporting documents and
and also your staff and include
service, getting it right first
all these stakeholders in your
time. Ultimately, this will save
planning. a lot of time, money and
These are possibly two of management stress later when
the biggest regulatory issues the FSA come knocking.
Insurance Brokers’ Monthly 23
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