Regulatory Consideration which are Relevant to MGAs:

Ensuring that ‘appropriate resources’ are maintained in all areas of the business (to meet FCA Threshold Conditions)

Considering whether any key staff with children of school age can utilise the ‘key workers in financial services’ provisions. 

Ensuring there is adequate capacity within the business for dealing with customer complaints, allowing for the emergence of new circumstances which may give rise to a complaint.

Increasing vigilance on other operational risks which may crystallise during this period of business vulnerability (e.g. financial crime).

Considering whether any additional measures taken to protect the business are consistent with regulatory requirements.

Continuing to act in customers’ best interests, recognising and responding to new ‘vulnerable’ customer considerations.

Considering the TCF implications for matters such as:
      •    inability to pay premiums within normal terms of credit
      •    policy cancellation requests where there may be no refund

Considering the implications for supervision and monitoring of staff who are now working remotely.

Considering any impact the current situation will have on meeting regulatory capital and other financial requirements.

Monitoring the financial strength of the insurer(s) from which capacity is sourced 

Many thanks to CMS for supplying this.

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