Insurance2day Insurance Services Ltd – New Business Procedures

Initial Contact

Insurance2day Insurance Services Ltd (I2D):

  • Requires that any member of staff talking or corresponding with a potential client conducts themselves in a manner that reflects well upon the company.
  • Expects each representative to act with due skill, care and diligence and observe high standards of integrity and deal, professionally and fairly with prospective customers.
  • Representative must only discuss matters in which they are competent and refer matters requiring more specialist advice to their supervisor/manager where necessary
  • In respect of Consumers, the I2D representative must act in accordance with the Customers Best Interests Rule and at all times pay due regard to the interest of its customers and treat them fairly.

All prospective customers are to be provided with the following details:

  • The name of the I2D representative, the fact that he works for
    I2D.
  • That I2D is an intermediary and will act on behalf of the prospective client in arranging their insurance.
  • That I2D is authorised and regulated by the Financial Conduct Authority and conforms to the FCA Rules and Regulations to ensure that customers are treated fairly and in accordance with the Customer’s Best Interests rule.
  • The firm’s authorisation can be checked by visiting the FCA website or by contacting the FCA by telephone.
  • Whether we will provide a personal recommendation based on a fair and personal analysis of the market or from a limited number of insurers or from a single insurer. (N.B. Personal means it is presented as suitable for the person to whom it is made and NOT that it is made personally by an employee or director)
  • Where information is given on a basis other than a fair analysis of the market the firm must disclose whether it is contractually obliged to conduct insurance mediation activity in this way and provide the customer with a list of insurers selects from or deals with in relation to the contracts provided.
  • Information on how to register complaints

Much of the above information will be covered in our Terms of Business, therefore ALL quotes (new business and renewal) need to include the following text:

Our latest Terms of Business & Privacy Notice can be viewed online at:
www.insurance2day.co.uk/insurance-services-terms-conditions
www.insurance2day.co.uk/gdpr/privacy-notice
These clearly set out the basis upon which we trade and we would ask that you read carefully to ensure that our services are right for you. If you require a printed copy, please advise.

The I2D representative is to explain to the prospective customer the importance of a thorough information gathering exercise and:

For Commercial Clients: the duty of fair presentation including the requirement to disclose every material circumstance which the insured knows or ought to know when informing I2D of their demands and needs. The prospective customer must be informed of the consequences of any failure to disclose material circumstances. ALL Commercial Quotes (new business and renewal) need to include the following text:
In accordance with the Insurance Act 2015, as a purchaser of commercial insurance you have a duty to disclose every material fact that you know, or ought to know, about the risk. A material fact is something that would affect the judgement of an insurer in deciding whether to accept the risk and on what terms: at inception, renewal and on variation of the policy. This information must be disclosed in a clear and accessible manner, after all necessary enquiries have been made, to ensure that the information provided is both complete and accurate.
The duty of fair presentation has been created to ensure fairer outcomes in the event of a claim, however failure to make a fair presentation of the risk may result in an insurer avoiding the policy and refusing all claims and, depending on the circumstances, premiums may not be returned. Further details can be found at: www.insurance2day.co.uk/disclosure-material-facts

For Consumers: the necessity for the prospective customer to answer all questions honestly, accurately and to the best of their knowledge. The prospective customer must be informed of the consequences of any failure to provide accurate answers. ALL Consumer Quotes (new business and renewal) need to include the following text:
Please note that it is your duty to take reasonable care to answer all questions honestly and to the best of your knowledge.  If you do not, your insurance policy may be cancelled or treated as if it never existed or your claim may be rejected or not paid in full.  It is important that all statements you make on proposal forms, claim forms and other documents are full and accurate. If a form is completed on your behalf, you should check that the answers shown to any of the questions are true and accurate before signing the document. Failure to provide requested information to your insurers could invalidate your insurance cover and mean that part or all of a claim may not be paid.

The I2D representative is to take appropriate steps to understand the type of customer that they are dealing with and the extent of the customer’s knowledge and awareness of risk and general insurance cover.

A I2D Fact Find must be fully completed. The representative must seek sufficient information about the prospective customer’s circumstances and objectives, including details of any relevant existing insurance arrangements, in order to identify the prospective customer’s demands and needs. The Fact Find (in whatever format) must be retained for a minimum of six years.

For Commercial Clients, when collating information about the risk the I2D’s representative must involve / identify people who know the risk, can present the risk information and senior personnel who can sign the information off as accurate. The knowledge of the senior management team, the risk and insurance team and the knowledge held by third parties e.g. accountants, solicitors and insurance brokers must be included.

Timeframes must be set for I2D to report to the prospective client with the results of the broking exercise and subsequent recommendations.

All information provided by the prospective client must be treated as confidential as described in our Terms of Business document.

Sanctions Checks

A check of the HMT Sanctions List should be carried out as appropriate and this must be documented. Sanctions Checks are to be performed by logging into our account here:

https://www.sanctionssearch.com/Account/SignIn
Username: Insurance2day.co.uk
Password: 5fcc1899
Email Address: er@insurance2day.co.uk

Meeting with a Prospective Customer

In addition to the points mentioned above, the I2D’s representative must comply with the following when the initial contact with the client involves a meeting:

  • I2D requires that any member of staff visiting a potential client present himself/herself in a manner that reflects well upon the Company. The staff member should be well groomed and dressed smartly.
  • Where a motor vehicle is used for transport to the prospect’s place of business, such vehicle should be clean and in a good state of repair.
  • The I2D representative is to pass a business card and any relevant promotional material to the prospective client and advise that any terms we propose will be subject to our standard Terms of Business . An explanation of the contents of the Terms of Business document is to be given where necessary.

Broking

A broking exercise in line with the scope of service being offered is to be carried out.

Electronic Quote Systems:

  • A copy of the document showing a summary of all quotations received is to be retained.
  • Full details of the quotation being proposed to the prospective customer is to be retained on the shared drive, either in subfolders of the Client Presentation & Reports folder, or in the Scans folder for the relevant month.

Manual Quote Procedures:

  • The timing of a presentation to insurers must be such that it enables Underwriters sufficient time to fully consider the information provided and make further enquiries where necessary to reveal undisclosed material circumstances.
  • Insurers must be telephoned within two days of the presentation being sent to ensure that it has been received and that Insurance2day Insurance Services Ltd ’s interest has been logged on insurers’ quote administration system.

Broking Records

A Broking Sheet from the shared drive should be completed for each risk, logging details of verbal/telephone quotes, along with all other terms and is to be updated as and when quotes are received. These sheets should be saved either in subfolders of the Client Presentation & Reports folder, or in the Scans folder for the relevant month.

Quotations

Formal written quotations are to be provided to the prospective customer within the timeframes agreed so that the prospective customer may fully consider I2D’s quotation and make an informed purchasing decision.

If the quotation is to include an Optional Additional Product, this must be sold on an opt in basis with the customer being given appropriate information about the product in good time to make an informed purchasing decision. The firm’s procedures for the sale of Optional Additional Products must be followed.

Even when the insurance proposal is discussed with the client face to face the client must be provided with the following information in a durable medium prior to conclusion of the contract:-

• A brief description of the client’s demands and needs specifying that they are based on the information provided by the customer as more fully described in the I2D quote document. The demands and needs statement should include the underlying reason for any advice / recommendation given.

• The website link to I2D’s Terms of Business document & Privacy Notice

• The scope of service the firm has provided in relation to the policy proposed e.g.
o We offer products from a range of insurers based on a fair and personal analysis of the market.
o We only offer products from a limited number of insurers for ………….. insurance. We will provide you with a list of these insurers.
o For …………… insurance we deal exclusively with ……………….

• Appropriate information about the policy in good time and in a comprehensible format enabling the client to make an informed purchasing decision. The information required will depend on the complexity of the policy, the knowledge and ability of the customer and whether they have purchased such a policy previously. As an indication appropriate information should include:-
o Insurer, type of insurance, cover and period of insurance
o Subject matter of insurance (including for example: use, occupancy, etc.)
o Sums Insured, Limits of Indemnity and benefits
o Excess(es)
o Any significant or unusual Conditions, Extensions, Limitations or Exclusions including whether the insurer has contracted out of the Insurance Act 2015 (the policy wording must be reviewed to check if the insurer has opted to contract act, as this is more onerous and would need to be flagged up as an issue).
o The customer’s attention must be drawn, to any significant or unusual exclusions.
o Warranties and Obligations.
o Any differences between the prospective client’s demands and needs and the insurance proposed.
o Premiums, fees, tax and total amount due for all insurance products and services and when they will be reviewed.

• What services I2D provide, e.g.
o We will advise and make a personal recommendation for you after we have assessed your needs.
o You will not receive advice or a recommendation from us. We may ask some questions to narrow down the selection of products that we will provide details on. You will then need to make your own choice about how to proceed.

• Any advice or recommendation must be explained in relation to the client’s demands and needs.

• Clear and appropriate information on payment options and the different costs associated with these payment options including interest charges, the APR, the instalment amount and credit arrangements. The cash price of any policy must be clearly shown.

• Major areas of risk which are not currently insured.

• Non-insurance products not covered by FCA rules (e.g. uninsured loss recovery, breakdown/recovery).

• How long the prospect has to take up the insurance on the terms quoted.

• Any other areas relevant to the client’s demands and needs.

In addition, for Consumers:

  • Insurers are required to produce an Insurance Product Information Document (IPID) these must be forwarded to the consumer and the importance of reading the IPID drawn to their attention.
  • If the quotation is in respect of a Motor Policy and includes optional No Claims Bonus Protection Discount then the I2D Representative must ensure that the NCB Protection Statement and the NCB Protection Information are provided to the consumer.

Note: I2D’s commission must be disclosed promptly (if requested by the customer). The disclosure must be in cash terms (estimated if necessary) and in writing or other durable medium. If this is not possible the intermediary must give the basis for the calculation. The procedures in this manual for commission disclosure should be followed.

Telephone Quotations

Where quotes are provided verbally, a Q Template or Commercial Presentation document must be issued and provided to the prospective client, PRIOR to cover being issued.

Appointment of I2D

The I2D representative will:
• Where possible, seek written confirmation from the client that they wish to employ the services of I2D
• Advise the client that all cover will be confirmed in writing.
• Use their skills objectively in the best interest of the client when choosing an insurer with whom the client’s business will be placed.
• Seek written acknowledgement from the client, where instructions are received to place the insurance, which are contrary to the advice given by I2D.
• Provide the client with a telephone number or address to which a claim may be notified.

Confirmation of Cover, following acceptance of a quotation

  • The I2D representative will email the insurers confirming cover is to be incepted and request written acknowledgement that cover has been placed or accept the online quotation on the insurer’s system. A copy of the email is to be attached to the TAM Client Record.
  • The I2D representative will write to the client immediately the placement of cover has been completed to confirm that cover is in place. A copy of the Cover Confirmation email is to be attached to the TAM Client Record.
  • The policy document including all certificates must be supplied promptly to the customer. Where policy documents are not immediately available this must be diaried and the documents chased. The TAM system is to be used to diary any document chasers and copies of all quotes, broking communications and documents are to be attached to the TAM Client Record.
  • What to do in the event of a claim including the address, telephone number or other point of initial contact for notifying a claim and the information the customer must provide to the insurer when notifying a claim must be supplied to the customer. This is included in our covering emails / letters to send documents to clients.
  • For Commercial Clients, where a Proposal Form is to be completed, the I2D representative must draw the client’s attention to: the duty of fair presentation and the need to disclose material circumstances known to the client and to answer questions accurately.
  • For Consumers, where a Proposal Form is to be completed, the I2D representative must draw the client’s attention to: the importance of answering all questions honestly, accurately and to the best of their knowledge.
  • The client is to be supplied with a receipt for the payment of premiums, fees and charges.
  • The I2D representative will remind the client of any services of which the client has not availed themselves.
  • Group Policies. In addition to the above, the I2D representative must inform the commercial customer that he should provide a policy summary to each person deemed to be a policyholder under the policy and inform them that a copy of the policy document is available on request.