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Markel Tax

27 Jun 2018

Insurance Distribution Directive

The Insurance Distribution Directive (IDD) comes into force on 1 October 2018. The purpose of the Directive is to protect customers who are buying general insurance; this includes the purchase of fee protection insurance.

Practice Protector Policy

Where your firm operates a Practice Protector Policy with Markel Tax, you are the Policyholder and also the Insured Party. Insurance regulation flows between Markel Tax and your firm (the consumer) and the IDD regulations apply at this level. 

Your firm’s policy enables you to make a claim for compensation in respect of the fees that you would have charged in dealing with the enquiry for a client that has subscribed to your Tax Investigation Service.

You are not providing insurance to your clients; you are providing a Tax Investigation Service. This service is not governed by the IDD and you are not utilising a Designated Professional Body (DPB) Licence as you are not providing a contract of general insurance. As such, you will be unaffected by the introduction of the IDD and you need take no action.

Client Protector Policy

Where your firm operates a Client Protector Policy, your firm is acting as a regulated insurance intermediary and so will be governed by the IDD after 1 October 2018. Furthermore, we are aware that the ICAEW is currently reviewing the changes that will be made to its DPB (Investment Business) Handbook to ensure compliance with the IDD. A firm will also need to consider these changes if you are operating under a DPB Licence from ICAEW.

Amongst other things, the following requirements will apply:
  1. For a contract of general insurance (such as fee protection) you must provide to your clients a standardised insurance product information document (IPID) drawn up by the manufacturer of the contract of general insurance. An IPID is a short summary of the policy and presents relevant information about the insurance policy in a standardised format. We will provide this to you at renewal of your Policy.
  2. You need to provide your clients with all details of the nature of the remuneration received by you in relation to the contract of insurance. All details includes the amount of any administration, service fee or commission whether you get this remuneration through the retention of part of the client’s premium, or a separate rebate, commission or any other payment.

Client Decide Direct

This is a scheme where your firm writes out to clients, but clients then respond directly and pay their premiums to Markel Tax and your firm may well receive a commission for the introduction. Where your firm operates on this basis, clients are still buying fee protection insurance and so the sale will be governed by the IDD. This is the case whether your firm is licensed to recommend insurance or is simply providing the insurer’s information to the client.

Your area sales manager can discuss the IDD requirements and provide guidance on the options available to your firm now or during your renewal meeting to ensure that you remain compliant. You can either contact them directly or call 0345 223 2727.
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