Welcome to our August Regulatory Bulletin - with the GDPR dust finally settling, it's now time to ramp up our focus on the changes we're making to be fully compliant for the Insurance Distribution Directive and the Brexit Part VII transfer process.
August Regulatory Bulletin
The Insurance Distribution Directive comes into force in just under two months and as no doubt you are aware, there are changes you will need to make to the way you operate in order to be compliant with this legislation. As mentioned in previous communications, here are three key areas you may want to focus on:
1. Your online presence
Is your website set to be ready for the IDD? There are some fundamental changes to the way products and policy documents can be offered online. It’s unlikely that your current website is compliant, so please make sure you’re ready when 1st October comes around. These changes are also applicable to offline business.
- Ascertaining a customer demand and need for the product before the product is offered
- Offering paper policy documents with equal weight to email, free of charge
- Disclosure of remuneration received by your business from the product provider
2. Insurance Product Information Documents (IPID)
The new market standardised IPID is a customer facing policy document that must be provided both pre and post policy bind. The IPID will help make it easier for our customers to compare cover between different insurers to allow them to make a more informed choice when choosing a policy. For open market UK based business, IPIDs will be provided to you to issue to the customer within the policy documentation. If you write business based in Ireland, an IPID will be provided on our broker centre. If you hold a delegated authority, an IPID will be provided for you to issue and or implement into your systems and website. Please ensure you have this set up in time, including for renewal invites sent for policies renewing on 1st October 2018.
2. Product Oversight and Governance (POG)
As a distributor of insurance, it is your duty to establish certain information about the product that you are selling. At Hiscox, most of our arrangements with you we act as the manufacturer of the product and have a duty to make this information available to you, to ensure that the product is offered to those it is suitable for and through an appropriate distribution method. We will be providing POG information through our broker centre, unless you have a scheme or delegated authority with us, whereby we will email you this information before the 1st October 2018. If you have any POG questions, please do not hesitate to contact our IDD project team on uk&[email protected] where we will happily answer any questions or address any concerns you may have.
Communicating with policyholders
As you will already be aware from last month’s bulletin, Hiscox is in the process of a Part VII transfer to move all live policies and historical liabilities that could be impacted by the loss of passporting rights from Hiscox Insurance Company Limited to Hiscox S.A. to enable us to continue to serve our customers and claimants post-Brexit.
Our Directions Hearing took place last week, and this is where the High Court approved our materials and our approach to communications. This means we are now able to start communicating to those relevant Hiscox policyholders.
What happens now?
We will begin writing to those policyholders affected by the Part VII transfer on 13 August 2018.
Each customer we contact will receive a letter and a scheme booklet from us which will contain:
- a summary of the proposed transfer;
- a summary of our independent expert’s report on the impact of the Part VII on our customers;
- notice of the proposed transfer;
- some additional questions and answers; and
- details of how they can contact us
Customers will then be able to ask any questions or raise any objections they may have until the date of our sanctions hearing, currently scheduled for 14 December 2018.
How you can find out more
Our dedicated Part VII website, www.hiscoxgroup.com/partvii, has electronic copies of all of these documents as well as:
- more information about the Part VII transfer; and,
- our full Q&As on the Part VII process and how it affects our customers.
For brokers located in the Republic of Ireland or Jersey, documentation is available on our website which will have information relevant to you.
We also have established a dedicated Part VII team to answer any questions you or your customers may have, which you can reach on 0800 7813 049 or by emailing [email protected]. You will also find some Frequently Asked Questions on our website – www.hiscoxgroup.com/partvii.
Thank you to all of you that have now signed and returned your amended contracts. For those of you still yet to return your signed contracts, please ensure you do so as a matter of urgency so we can continue to do business together. Should you wish to contact us regarding your amended contract please email us at uk&[email protected]