MGAA Personal Lines Insights – April 2024


03/04/2024 | Online Zoom Conferencing and In-person at the Business Lounge, 1 Minster Court

Mind the GAP: Fair Value and the FCA Product Governance Thematic Review

Time: 10:00 am – 11:00 am

Where: Online Zoom Conferencing and
Face to Face at the Ground Floor Business Lounge, 1 Minster Court 

Please note: If you are attending in person, 9.30 – 10am & 11 – 11.30am will be a networking opportunity. 

The FCA have taken decisive action against the GAP insurance market for its failure to effectively implement Product Governance and Fair Value rules to the satisfaction of the regulator. In a subsequent letter to all market participants dated 23rd February, the FCA warned that it was “…not the only product where we have these concerns”, issuing an unprecedented early warning letter ahead of the full report due in Q2 2024 on its Product Governance Thematic Review. Kenneth Underhill will provide an overview of the Fair Value rules, looking at:

  • The issues GAP insurers failed to address to the regulator’s satisfaction;
  • What the FCA has now asked all firms to do; and 
  • How firms can establish whether any of their products might be next in the firing line and be prepared for the full consultation paper which is expected in Q2 2024.

This will be an interactive session and audience participation will be encouraged.

Learning Objectives

At the end of this session, delegates will be able to:

  • List the issues raised by the FCA when it took action against GAP insurers;
  • Explain the reasons why the FCA took the action it did;
  • Explain what action the FCA has demanded all firms must now take and by when;
  • Summarise how to assess its employer’s own products key metrics against those being used by the FCA as benchmarks.
  • Be able to explain how the interim action taken by the FCA fits within its wider Thematic Review on assessing insurance manufacturers’ and distributors’ product oversight and governance arrangements.

About the Presenter

Kenneth Underhill, Founder

Kenneth Underhill has almost 30 years in the London Insurance market and is the former General Counsel of Chubb European Group, then ACE. A Director of multiple Insurance Companies operating in over 30 countries with a turnover in the range of $5+billion, he was responsible for Legal, Compliance and Corporate Governance across the EMEA region and had a team of 60 or so.

Prior to that Kenneth was a founding partner of the Commercial & Regulatory team at Reynolds Porter Chamberlain. Kenneth founded ICSR in 2017 and has led the firm through successive years of exponential growth, helping a wide range of insurance firms with the establishment, operation and remediation of their businesses.