Insurance Regulation

[homeprotect_uk]

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Hi
I would like to introduce an affiliate programme for our homeprotect product but I first need to explain to our compliance team how I can work with affiliates which are either not directly authorised by the FSA or appointed representatives of our company.

Can anyone explain this to me please? The FSA's Perimeter Guidance Manual (PERG) states (PERG 5.6.18) that the only way an 'introducer' can remain non-authorised is if they are "completely indifferent as to whether or not a contract of insurance may ultimately be bought (or sold)". It goes on to say "This is likely to be the case where the introducer does not receive any pecuniary reward that is linked to the volume of business done as a result of his introductions."

So my question is, how can non-authorised affiliates promote an insurance product?

Thanks for your help

Gerry
Avantia Insurance

[H3Consultancy]

Hi Gerry


Unless you can persuade the affiliates to provide leads for no reward (monetary or otherwise) then you can't do this without notifying the FSA one way or another.

The normal way for a regulated firm to add 'affiliates' for insurance products is to register them as Introducer Appointed Representatives. This usually the route taken for dentists offering dental plan cover or vets offering pet insurance. Using the IAR option is somewhat less onerous for both the regulated firm and the affiliate than making them a full Appointed Representatives, BUT allows the FSA to keep tabs on the firms that might otherwise be entering into regulated activities without being authorised to do so. Hope this helps.

H3 Consultancy are a compliance consultancy specialising in helping mortgage and insurance intermediaries.