The FSA has criticised the use of implied terms in policy documentation.

Speaking at the CII conference, FSA director of high street firms Sarah Wilson said that senior management must make “urgent” changes to its documents.

“At present there is an inappropriate reliance on unwritten terms. The industry needs to show it understands its obligations,” she said.

Wilson also warned the industry about the lack of awareness of regulation among secondary intermediaries.

“This is a commercial problem for insurers and brokers. We have written to chief executives, but the market must re-double its efforts.”

Wilson said that information from product providers was the most effective medium for raising the awareness of secondary intermediaries. “The industry's future is in its own hands.”

She also emphasised that the FSA would be closely monitoring the perimeter of regulated activities after 15 January 2005.

“Early on we will focus on unauthorised firms who are doing regulated activities,” she said.