The introduction of specialist faculties is an important step in underpinning the regulatory code of conduct, but GISC was there first. Robin Wood explains
An invitation floated through my letter box this week from the CII. It was a personal request that I attend the launch of the CII Claims Faculty this month. I shall be there.This event triggered recall of the announcement by Eric Galbraith at the Biba conference in May that the largest trade association for brokers was supporting the CII Broker Faculty launch in October. Our other major broker trade association, the IIB, must surely follow suit and support this venture.Being something of a newshound, I have undertaken a bit of digging on behalf of CPD readers because a good quality faculty is going to be a profoundly important ally to individual practitioners and firms under the FSA regime.I discovered that there was a plan for a London Market Faculty. That is great news. It has taken a decade to convince the regulators, the industry and the courts of this. While the underpinning principles of good conduct are common to the whole of the industry, different parishes operate in different ways and none more so than the London and non-London markets.What this means is that 100,000 plus practitioners in the insurance broking world can look forward to a faculty that really represents them without any inappropriate influence from elsewhere.
Defining standardsIt also seems very clear that the faculty is not about the same old faces popping up to sit on committees and drink tea (I am being polite). Instead it is about brokers representing themselves in the matter of defining standards and with full representation of all parishes, creating an environment where a broker's views can and will be heard.What I particularly like about the faculty model that is developing is that the CII is focusing on adding value to members by establishing standards of good and best practice. It is also aiming to give individuals and firms a cocoon of professionalism and respect, if you like, a real identity in a world of indifference.It will be a challenge but I am confident the CII will be able to deliver the advantages of membership of a good faculty. These are:
Regulation experienceFrankly, if GISC had not existed, it is my opinion that FSA regulation would have been a bloodbath. Many thousands of firms and hundreds of thousands of individuals would have had little experience of regulation and good business standards and the area of competence assessment and learning would have been very barren indeed.Instead the GISC had created a world of awareness of our duty to our customer, and an awareness of our own lack of knowledge and skill. Continuing to work in the GISC manner remains the foundation of a compliant FSA existence.Looping full circle we return to the matter of the faculties and codes of conduct. Learning point number two is the recognition that the GISC codes of conduct disappear on 13 January 2005. The FSA sets high level standards and there is a code of practice for approved persons, but day-to-day good market practice remains the domain of the market itself.The faculties will feed honed and specialised codes of conduct into the FSA regulation and rules. This will provide the benchmark of what the industry regards as good practice. That's what I like about what I hear so far about the faculties.
Representative bodyA truly representative body that is run by my peer practitioners adds value to me, my family and my career and allows me to claim to be a Member of the Faculty of Insurance Brokers. This is a title that any practitioner who is competent to do his job should have access to.Let us see how it unfolds. I will keep you posted on this page.The final point this week is on the 'minded to authorise' bandwagon. Please don't forget that you have declared that you will be compliant by 14 January 2005 and the FSA may want to know how you expect to get there. You are now bound by the FSA disclosure rules, so if anything material changes from the information given on your application, you need to tell the FSA.There are far too many brokers for comfort sitting back and thinking, "that is all there is to it". One broker has reported to us that they have been told by an alleged compliance expert that the FSA has so much to do that anyone with less than £1m brokerage has little chance of having their application checked. Let me put another proposition to you. The FSA has the finest intelligence service outside the secret service known to man. Do you really think that the only information they have on you is that which you have sent them?From the T&C perspective make a start if you have not already. It will take a few months to get compliant if you have not done so yet.