RegSol Blog

Central Bank Intermediary Times November 2023 Issue

November 2023

The 'Intermediary Times', the Central Bank of Ireland’s (CBI) newsletter published twice a year, includes regulatory issues that retail intermediary firms need to be aware of in improving their standards of compliance.
  • In this edition the newsletter covers many items including:
  • Updates on the Fitness and Probity (F&P) requirements;
  • Professional Indemnity Insurance update;
  • Update on the Consumer Protection Code review;
  • Information on Client Premium Accounts.

1. F&P Requirements Update

Annual Pre-Approval Control Function (PCF) Confirmation

The CBI advise that from Q1 2024, the annual PCF confirmation return will be submitted under the F&P section of the Portal.

In preparation for the return, firms should ensure that all PCF information is up to date; i.e. PCF start dates and PCF resignations have been submitted in a timely manner.

The CBI will publish Guidance on its website in advance of the go live date.

New F&P Application Guidance

The Central Bank reminds firms it released new F&P application Guidance (HERE) which should reviewed to submitting an Individual Questionnaire (IQ) or updating PCF information to find information on the new IQ application form and the expected due diligence firms are required to conduct and guides on how to use the system.

2. Professional Indemnity Insurance (PII) Update

Firms should be aware of the potential upcoming amendments to PII levels.

Minimum PII levels are reviewed every five years by the European Insurance and Occupational Pensions Authority (EIOPA). The current review is underway with proposals sent to the European Commission in June 2023.

Firms are reminded to continue to ensure compliance when the new PII levels are approved. Where there are changes, the CBI it will issue further guidance.

3. Update to Consumer Protection Code Review

The Consumer Protection Code is currently under review with a view to publishing a revised Code.

The next steps in the review will be Public Consultation, where the CBI will seek views from interested stakeholders on the proposed changes to the Code, and Finalisation of the revised framework. Following the public consultation, the CBI will consider the feedback and insights before publishing the final revised Code. A feedback statement will also be published at this time, setting out the rationale for the CBI's approach.

4. Client Premium Accounts

Insurance Intermediaries must have robust procedures and oversight arrangements in place to ensure that monies received in relation to client premiums are segregated from other monies in the firm. The CBI reminds such intermediaries that transactions through Client Premium Accounts (CPAs) should be conducted in accordance with the Consumer Protection Code (CPC):
  • Payments in respect of levies, membership fees, or other transactions not specified in Provision 3.50 of the CPC are not permitted to be made from a CPA;
  • CPAs must be clearly designated ‘Client Premium Account’ to ensure that client premiums are segregated from other monies;
  • A separate CPA must be maintained for both life and non-life insurance business;
  • A CPA must never be overdrawn;
  • Firms are required to carry out, and retain, monthly reconciliations of amounts due to regulated entities; and
  • Firms should ensure that rebates due to consumers are processed correctly and in a timely manner. Where rebates are issued by cheque and not presented for payment within six months, the payment should be returned to the Insurance Undertaking.
To read the CBI publication in full, please see the link below:

Intermediary Times - November 2023 (