Insurers’ post-transition TOBA requests require scrutiny 

A number of brokers and intermediaries who have placed cover for clients’ assets in other EU or EEA countries have recently received requests from insurers to sign new TOBAs. 

The theory is that having the broker sign an updated TOBA will enable them and the current insurer to continue providing cover for UK clients’ assets in certain EU member countries. 

We would strongly recommend, however, that any broker or intermediary tempted to take this on trust and sign on the dotted line should pause first and think very carefully about the potential implications.

Any lack of clarity over the precise status of your involvement in arranging cover for UK clients with assets overseas after the Brexit transition period expires could leave you in an uncomfortably exposed position.

Different EEA countries have significantly different local rules and interpretations of regulated activity. So it’s essential you look closely into whether and how your continued involvement conforms with all applicable legal and regulatory requirements.

If you’ve been encouraged to sign a new TOBA to continue providing a service to HNW or other clients’ overseas assets and you’d like to discuss this with one of our compliance experts, you can contact us on 01925 765777, or email us at

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