In PS21/5 the FCA confirmed Senior Managers must attest annually that their firm has complied with General Insurance (GI) Pricing Practices rules found in ICOBS 6B.
A survey, together with covering letter, was sent out in January to premium finance providers and firms with GI permissions to facilitate the first annual attestation. The attestation is to be completed by firms who provide or sell the core motor and home insurance products and who have a price-setting role, attesting for the portion of the price set by the firm (excluding fees). As the survey has been sent to all firms (premium finance providers and those with GI permissions) some firms who receive the survey will not be subject to the rules. If your firm is in this group, you need to submit a nil return as confirmation that your firm does not undertake any pricing activity in relation to all products in scope. You can do this by selecting Option 10- none of the above and complete details of the appropriate Senior Manager. All firms that received the survey must respond in full, or provide a nil return, by 31st March 2022.
Whilst Qualtrics has been used for this first attestation the second, and all subsequent annual attestations, will be completed through RegData.
For the second (due March 2023) and subsequent attestations, the reporting period will be annual, 1st January to 31st December with the reporting due by 31st March the following year. There will be questions that will allow the required notification by firms which are price-setters by virtue of commission rebating / discounting (i.e., the notification if more than 25% of home or motor sales include commission rebating / discounting).
This Attestation is a statement with significant importance and should be given appropriate consideration by the Senior Manager with the responsibility for its completion; they must be satisfied that the firm has sufficient evidence available to establish that the firm is operating in compliance with the rules.
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