CHO Training Support Iain Stephen Jt. 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

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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 or

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 members Compliance advice Authorisation Audits Monitoring programmes Training Iain Stephen Office Mobile