This week Compliance Zone tackles the Insurance: Conduct of Business rules (ICOB). These rules, which deal with the treatment of clients and the sales process, are some of the most difficult for brokers to implement because to do so involves changing working practices.

Over the years brokers and their firms will have developed their own tried and trusted ways of dealing with clients. But the FSA will require them to change that.

For many this will be quite a shock, not least because of the additional administrative burden that is required to prove to the regulator that the rules are being followed. In the new regulatory environment documentary proof is essential. In the FSA's eyes, if an audit trail is not present, the procedure wasn't followed.

Michael Faulkner

If you have received a 'minded to authorise' letter, email: