Based on our discussions with the industry, we have compiled various scenarios, which we believe reflect the various connected travel insurance (CTI) business practices that occur in firms.

The examples run through various stages of the sales process, showing when a firm falls within – and outside – regulation.

They describe particular situations and you may be doing a combination of what is described below, in which case you should be aware of the overall implications of your activities.

Firms who are currently regulated for standalone travel insurance that also carry on CTI may also find the scenarios helpful.

Scenarios

Displaying leaflets advertising connected travel insurance.

This is not a regulated activity.

Giving a customer a leaflet advertising connected travel insurance (with or without an application form).

You can rely on an exclusion (giving a customer incidental information) even if you receive commission from a subsequent sale of CTI.

Providing an application form within travel brochures that the customer may remove and complete - this application must be sent back to the insurance broker/insurer (rather than the travel firm) by the customer.

You can be excluded from regulation (giving a customer incidental information) even if you receive commission from a subsequent sale of CTI.

Giving a customer factual information for them to include in an application form.

If you are just giving information and if that is the extent of your involvement then you can rely on an exclusion from regulation (giving a customer incidental information).

Giving a customer the contact details of an insurance broker or insurer.

If you are just giving information and if that is the extent of your involvement then you can rely on an exclusion from regulation (giving a customer incidental information).

Having a direct link on your website to the website of a travel insurance broker or insurer.

If you are just providing a means whereby the customer can communicate with the broker / insurer and if that is the extent of your involvement, you can be excluded from regulation (enabling parties to communicate).  This applies even if you receive a commission from a subsequent sale of CTI.

Having a separate internet or telephone access in the office for customers to use.

You can be excluded from regulation (enabling parties to communicate).

Passing customer contact details to an insurance broker/insurer.

This is introducing. You would need to be an introducer appointed representative (IAR) as a minimum.

Passing a completed application form to an insurance broker/insurer on behalf of a customer.

This is considered to be arranging so IAR status would not be enough. You would need to be a full appointed representative (AR) or an authorised firm to do this.

Helping a customer complete an application form (either written or online).

This is arranging and you would need to be either an AR or an authorised firm with a permission to arrange.

Acting as a conduit between the customer and the insurance broker/insurer.

This is likely to be arranging and you would need to be either an AR or an authorised firm with a permission to arrange.

Receiving a combined cheque for the holiday and the travel insurance.

This is arranging and you would need to be either an AR or an authorised firm with a permission to arrange.

Recommending that a customer takes out (or does not take out) a specific CTI product.

This is advising and you would need to be either an AR or an authorised firm with a permission to advise.

Stating that a customer should take out travel insurance in general. The package regulations require a firm to tell customers of the availability of travel insurance.

If you are just giving generic advice and if that is the extent of your involvement then you are neither providing regulated advice (which is specific to product) nor arranging.

Stating that a CTI product might not be suitable for the customer because of certain exclusions. For example, that a specific CTI product does not cover individuals who are aged 80 and over.

As long as you do not recommend the customer not to buy the policy and you are just giving information, you can be excluded from regulation (giving a customer incidental information). You should consider whether the customer would understand that no recommendation is being made.