RegSol Blog

Central Bank of Ireland Enforcement Action – Keystone Insurance Limited

February 2021

On the 26th January 2021, the Central Bank reprimanded and fined Keystone Insurance Limited €41,385 for six breaches of the Consumer Protection Code from 2012 to 2017.

Keystone is a retail intermediary that operates in the commercial insurance market and is regulated under the European Union (Insurance Distribution) Regulations 2018.

The breaches included:

  • Overcharging: Customers were charged for placing insurance, processing mid-term adjustments and processing cancellations of insurance policies, in excess of the maximum fees allowed to be charged under Keystone’s Terms of Business.  62 customers were overcharged a total of €9,964.36 over a five-year period. These customers have been fully reimbursed by Keystone. 
  • Provision of unclear communications to customers: Out of 265 invoices reviewed, the Central Bank found that communication of applicable fees in 190 cases was unclear, in that the firm failed to bring fees to the attention of the customers. The information was on the invoices in small print at the bottom of the invoices.
  • Failure to have adequate systems and controls: There were inadequate systems and controls in place to facilitate Keystone meeting its regulatory obligations on communications.  

An aggravating factor in the investigation was that Keystone provided the Central Bank with incomplete and unclear responses to requests for information.  

Seána Cunningham, The Central Bank’s Director of Enforcement and Anti-Money Laundering said:

“The Central Bank expects that all regulated firms should have adequate processes, systems and controls in place to ensure compliance with the Code, ensure staff are trained on the Code’s provisions, regularly check that they are in compliance with the Code and ensure that any failures that may occur are identified and rectified early”. 

Click HERE to view the notice.

By Eilish Larkin
Compliance Consultant