The FCA has issued a ‘Dear CEO’ letter to General Insurance Intermediaries setting out its expectations for maintaining adequate arrangements that safeguard client money especially during the coronavirus (Covid-19) pandemic.
It reminds firms of their obligations to continue to oversee the CASS arrangements. It requires firms to discuss the contents of the letter with the board and agree what further action is necessary to help ensure adequate arrangements are in place, highlighting the following areas:
- application of client money rules to firm’s business model;
- governance and oversight;
- oversight of third parties, including due diligence;
- client money calculations and reconciliations;
- acknowledgement letters for all client money accounts.
You can find further information regarding client assets and coronavirus here.
Abridged advice – how is it going so far?
Alistair MacDougall Compliance 2015, 2018, 2020, 2021, abridged, Drawdown, FCA, Pension, Pension Transfer, PI, transfer
Based on data and live visits to firms during the period from April 2015 to rule changes in 2018 and 2020, the FCA believed that far too high a proportion of clients were being recommended to transfer safeguarded benefits. This was predicated on the longstanding rule which stated: “… a firm should start by assuming […]