Don’t forget about training and competence
We asked UKGI’s compliance experts to give us their thoughts on why Training and Competance (T&C) is good for firms, why you need to keep track of it and how it links in with CPD. This is what they told us:
The need for regulated firms to adopt a proper T&C programme for staff is a constant theme of FCA regulation. A firm’s T&C arrangement should provide the outcomes the firm requires not only in terms of the training and monitoring of staff, but also in terms of the firm’s wider business objectives. Well trained staff should mean better treated customers, and that’s got to be a good thing, right?
It's important that your employees have the knowledge and skills to complete their tasks and perform their duties, so in this article we’re concentrating on the ‘training’ element of T&C because it is closely linked to another FCA requirement for insurance firms – continuous professional development (CPD).
On 1 October 2018 the Insurance Distribution Directive introduced a 15-hour per year minimum CPD requirement, with specific knowledge and ability requirements in relation to insurance distribution. With everything else going on these days, from pandemics to pricing and product governance, it might be easy to lose sight of a looming CPD deadline if your firm chose to implement its annual CPD programme on 1 October 2018.
Your T&C arrangements must cater for the FCA’s specific CPD requirements which apply to all individuals directly involved in the firm’s insurance distribution activities, those responsible for supervising them, and those within the management structure responsible for those activities. The CPD should cover the terms and conditions of the policies offered by the firm, applicable laws governing the distribution of insurance products; claims handling and complaints handling, and assessing customer needs, amongst other topics. You should think about the kind of CPD that's appropriate for each individual or role, the way you go about delivering policies to customers (so your distribution model) and the nature of the insurance products you provide.
You might have access to plenty of information about the policies offered by the firm, well-established claims and complaints handling processes, and detailed guidance about how your staff assess your customers’ needs. But when it comes to applicable laws governing the distribution of insurance products (including the FCA’s rules), that’s where a pragmatic and solutions-driven compliance partner can be invaluable. As an example, we asked UKGI to create a video training session for us about that most important of issues – your regular contact with the FCA via your RMAR.
So, if some of your staff might need to understand the nature of regulatory reporting, and who might also need a quick top-up of some CPD hours, why not make the recording of the UKGI RMAR training session available to them? You can watch it here.