March 2008

The Financial Services Authority invites comments on this Discussion Paper. Comments should reach us by 25 June 2008.

You can send your response by electronic submission using the following form or by emailing us at the address shown.

Alternatively, please send comments in writing to:

Alison Phillip
General Insurance Policy
Financial Services Authority
25 The North Colonnade
Canary Wharf
London E14 5HS

Telephone: 020 7066 5198
Fax: 020 7066 5199

E-mail: dp08_02@fsa.gov.uk

It is the FSA’s policy to make all responses to formal consultation available for public inspection unless the respondent requests otherwise. A standard confidentiality statement in an e-mail message will not be regarded as a request for non-disclosure.

 

Note: You can take a printout of your response before clicking the 'Submit to FSA' button at the end of the form, but this will only print the visible text on screen, and you may have given longer answers. After submitting your response, the form will clear, but when we acknowledge receipt of your response by email, we can return to you a copy of your full submission as received. Check this box if you would like to have a copy of your submission returned:

Submission Details









as an individual
as a representative of an authorised firm
as a representative of a professional firm
other (please specify):

 

i) Do you have any comments on CRA’s market-failure and cost-benefit analysis?
ii) Do the wider market efficiency issues highlighted in this paper affect the cost benefit case for regulatory intervention, and how?

 

Do you agree that customers need to know the total remuneration earned by other intermediaries in the chain? If so, do you have any views on the logistics of providing the required commission information?

 

Do you agree that contingent commissions should be disclosed in cash terms and on a comparable basis? If so, what do you consider to be the best way of doing this?

 

Do you agree that intermediaries should provide information on the capacity in which they are acting – ie as agent for the customer or the insurer or both? How should this be disclosed?

 

We would welcome views on whether any particular arrangements / business structures give rise to unmanageable conflicts of interest?

 

Should we place any restrictions on what those describing themselves as ‘brokers’ can do?

 

Do you have any views on how we might best improve customers’ understanding of the breadth of search undertaken by their intermediary?

 

To what extent do you think we could rely on a customer education initiative to
help commercial customers understand the value of information about commission
and services?

 

We have made several suggestions in the paper about how to improve the comparability of information on both remuneration and services. Which of these do you think is likely to be most effective? Are there any other approaches you believe we should consider?

 

We would welcome comments on the relative merits – or drawbacks – of the three broad approaches outlined in Chapter 5. What other approaches (or permutations), if any, should we consider?

 

What are your views on the practicability of the options we set out and their implications for the competitiveness of the UK market?

 

Are there any other issues that you think we should consider?