The Central Bank has published a third edition and a special edition of the Intermediary Times. The purpose of the special edition is to provide advance notice to all registered insurance / reinsurance intermediaries of forthcoming changes to the professional indemnity insurance (“PII”) levels and clarification in relation to the inclusion of a specified retroactive date.

From 1 August 2013, all PII policies incepted or renewed by insurance or reinsurance intermediaries must provide cover for at least €1.25m per claim and €1.85m in aggregate per annum. From 1 August 2014, all registered insurance and/or reinsurance intermediaries must hold PII at these revised levels.

The Central Bank considers that all insurance / reinsurance intermediaries should hold continuous PII cover from the date of their registration, as the European Communities (Insurance Mediation) Regulations 2005 (“IMR”). Therefore, where a firm holds a policy which includes a specified retroactive date, it should ensure that:

  1. Any specified retroactive date is:
  • the date that the firm was registered as an insurance / reinsurance intermediary under the IMR; or
  • any date prior to the date that the firm was registered as an insurance / reinsurance intermediary under the IMR.
  1. If a PII policy with a specified retroactive date does not comply with (i) or (ii) above the intermediary must hold another PII policy or a comparable guarantee which provides satisfactory cover for the relevant period prior to the retroactive date specified on the current PII policy. All documentary evidence should be retained on a firm’s PII file as evidence of compliance with Regulation 17 of the IMR.

The Central Bank intends to commence a further thematic review of PII cover prior to the end of 2013.

Please click here to view the special edition of the Intermediary Times.

Issue 3 of the Intermediary Times covers matters including the following:

  1. Changes to the Annual Return:

A new Annual Return will be made available through the Central Bank’s web-based Online Reporting System (“ONR”) for firms due to submit Returns from June 2013 onwards. These changes are the result of a review of the format and ease of use of the Annual Return system that was introduced by the Central Bank in July 2011. The changes made to the Annual Return are minor and should not pose any difficulty for firms. Firms will be able to submit Returns using the new version from 17 June 2013. This will allow firms with a December 2012 financial year-end only two weeks to complete and sign off their Annual Return. The Central Bank has expressed regret in relation to the shortened timeframe, which it explains is due to IT requirements.

  1. Revision of the Handbook of the Prudential Requirements for Authorised Advisors and Restricted Intermediaries:

The Central Bank is revising the Prudential Handbook which has been in effect since July 2006. The revision is intended to reflect changes in the regulatory environment and to strengthen the prudential supervisory framework for investment intermediaries.

There will be a three month public consultation as part of the process. The consultation paper is due to be issued and will be available in the Consultation Papers section of the Central Bank website.

Please click here to view this section of the website.

  1. Report on the Retail Intermediary Sector:

A Report on the Retail Intermediary Sector was published by the Central Bank on 28 February 2013. This highlighted key issues and risks for the sector and consumers and outlined the Central Bank’s regulatory approach to reducing risk and ensuring that consumers are protected.

Please click here to view the report.

  1. Roadshows:

A series of regional roadshows will be held by the Central Bank in the second half of 2013. These roadshows will provide updates on topical regulatory issues and give attendees the opportunity to speak with the Central Bank in person. It is intended that the roadshows will take place in the South East and in the Midlands of the country in September. Suggestions for other locations should be sent by email.

Please click here to view the full text of the third issue of the Intermediary Times.