www.compliancy-services.co.uk@compliancysrvcs

CHO Training Support

Iain StephenJt. CEO

Compliancy Services Ltd.

Compliancy Services & The CHO

A long association since NACHO

Associate members since 2006

Member of the CHO Executive Committee

Support members/clients

- Authorisation - Ongoing retainer services - Training & Competence commitments - Audits and Monitoring strategies - Treating Customers Fairly (TCF) - Online e-learning modules & assessments

Offering expertise to entire membership

Credit Hire Industry under pressure from insurers

Promote united, consistent & professional service offering

Insurers want Credit Hire market regulated (obliterated!!!!)

CHO membership is currently subject to regulation

- c.80% of CHO members are either FCA authorised / MoJ regulated

- c.50% GTA members

FCA Regulated activity can only be performed if

Firm is directly authorised by the FCA

Firm is an Appointed Representative of a Principal firm directly authorised

- May only perform activities for which principal has permissions

Exempt firms

Professional bodies (e.g. Solicitors – SRA regulated)

FCA Regulated general insurance activities

The regulated general insurance activities (fully explained in Part 2 of FSMA):

Advising customers on non-investment insurance contracts

Arranging (bringing about) deals in non-investment insurance

Making arrangements with a view to transactions in non-investment insurance contracts

Dealing as an agent in non-investment insurance contracts

Assisting in the administration and performance of a non-investment insurance contract

Agreeing to carry out a regulated activity

Credit Hire firms activities caught by FCA regulation when doing

FNOL (first notification of loss)

- referred non-fault accident victim when notification to TPI of imminent claim

Advising/arranging general insurance contracts

- LEI policies - Insurance policies to mitigate failure to collect vehicle rentals from TPI

Handling claims against TPI on behalf of customers

- maintaining and managing the chronology of claims

Ministry of Justice

The Claims regulator: Kevin Roussell (a unit of the MoJ)

Run by Staffordshire County Council and regulates

Personal injury Claims Mis-sold financial services products/services

Employment / Redundancy claims

Criminal Injury claims

Industrial Injuries

Housing disrepair

Role of the Claims regulator

Licensing firms and individuals to provide claims management services

Take action against firms breaching regulations

Carry out regulatory and criminal investigations

Provide guidance and advice to consumers, organisations and regulated firms

Lead policy reforms for claims management regulatory system

Increasing consumers awareness of charges firms can make

Dealing with unauthorised firms offering claims management services

Basic principles of regulation

GOVERNANCE

CULTURE

CONTROL

What does regulation entail

FCA

Documented compliance manual Compliance monitoring programme Risk Assessment policy Governance policy Financial promotions policy Breach logs, procedures and classification of breaches Business Continuity/Disaster recovery plan Complaints procedure Training and competence strategy and documented scheme TCF policy / procedures and monitoring scheme Data Security / ICO registration Remuneration scheme

What does regulation entail

Claims Management Regulation

Complaints procedures

Data protection / ICO registration

Compliance Monitoring Programme

Introducer Registration form

Introducer monitoring sheets - (less than 25 paid referrals per quarter) or authorisation

Exempt Introducer’s register - reason for exemption

Remuneration scheme

CHO Training programme 2016 – available to members only

CHO Code of Conduct

Assisting Customers with Claims

Complaints

Approved Persons

Basic Insurance Principles

Compliance Monitoring

Data Protection

Health & Safety

Bribery & Corruption

Credit Hire Customer Support Knowledge

Supervision

FCA Regulatory Environment

Treating Customers Fairly

MoJ Compliance Monitoring

Additional insurer issues (e.g.) - rate evidence - rebuttal statements - pitfalls - impecuniosity - intervention

Login

Available Courses

The Company Dashboard

Training requests

Training available at subsidised rate for members only; - online via the CHO training platform, or - classroom in house if subject demands it

All requests for specific training subjects please contact Martin Andrews on

07730 517 699 or email mandrews@thecho.co.uk

A few compliance reminders

All customer service numbers should now be at standard rate (CRD)

Consumer Credit Interim permission slots last 3 months (FCA) or lost

Calculation of Credit Broking regulated income - if no direct commission then 5% + 0.5% of resulting loans

Complaints handling changes - no initial 4 week response and then 8 weeks final - changes again in 2016 immediate reference to FOS after final response

Connect system for all changes to firms status

General Insurance add ons: thematic review

Accessible to all CHO membersCompliance advice

AuthorisationAudits

Monitoring programmesTraining

Iain Stephen Office 01462 512020

Mobile 07885 962781

Email: iain.stephen@compliancy-services.co.uk