The price-setting Senior Manager Attestation – don’t sign lightly!

One of our compliance proposition partners – UKGI – gives an update on what’s required and things to consider:

“As if firms needed a reminder… but in its Policy Statement PS21/5 the FCA confirmed that a Senior Manager must attest annually that their firm has complied with the General Insurance price setting practices rules in ICOBS 6B.

A survey, together with a covering letter, was sent out in January by the FCA to premium finance providers and firms with GI permissions to facilitate the first annual attestation.

The attestation is to be completed by firms which provide or sell the core motor and home insurance products to consumers where the firm providing or selling the product has a price-setting role.

The Senior Manager completing the form will be attesting for the portion of the price set by the firm (excluding fees).

As the survey has been sent to all firms (premium finance providers and those with GI permissions) some firms which receive the survey will not be subject to the rules (if they don’t set prices for core home and motor insurance products). Even if your firm is in this group, you will still need to complete the attestation by submitting a nil return as confirmation that your firm does not undertake any pricing activity in relation to all products in scope.

You can do this by selecting Option 10 (‘none of the above’) on the attestation form and completing the details of the appropriate Senior Manager.

All firms which received the survey must respond in full or provide a nil return by 31 March 2022.

Don’t get too comfortable with the process though because, whilst the Qualtrics survey tool has been used for this first attestation, the second and all subsequent annual attestations will be completed through RegData.

For the second (due March 2023) and subsequent attestations, the reporting period will be annual, 1 January to 31 December, with the reporting due by 31 March the following year. There will be questions in these future attestations which will require notification by firms if more than 25% of their home or motor sales include commission rebating/discounting.

The attestation is a statement with significant importance and should be given appropriate consideration by the Senior Manager with the responsibility for its completion; the Senior Manager must be satisfied that the firm has sufficient evidence available to establish that the firm is operating in compliance with the rules.  Remember if you are the Senior Manager completing attestation the buck stops with you and under the Senior Manager Regime there are specific conduct rules which apply to you as an individual so make sure you are confident that whatever you are attesting to is correct!”  

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