LIKE any good modern regulator, the General Insurance Standards Council (GISC) has pushed training and competence (T&C) to the forefront of its policies.

The principle is simple – if staff and agents are (and continue to be) competent to do their jobs, if the service given to customers is of a reasonable standard and if members can keep a satisfactory record to show what has been done, then the customer should benefit. Business standards and results should improve and GISC members should be able to satisfy the regulator's requirements.

So far so good. The question is where to start when designing a T&C scheme. How do you create an environment in which thousands of GISC members from diverse areas of the general insurance business can communicate with each other, and with specialist advisers, in a common language and from a common set of underlying tasks?

Creating an industry standard
With no framework to work from, the problem can be compounded by many specialist advisers (from the major institutes to the one-man band) approaching the situation from different angles and with different terminology and management concepts. The result is mayhem.

The Financial Services National Training Organisation (FSNTO) is an independent organisation funded by the government and subscribing members, with the objective of providing training resources and assistance to the insurance and financial services industry. It doesn't provide training consultancy services – one of its major functions is to assist internal or external training specialists to achieve their own objectives, which ultimately is the improvement of quality and skills of the insurance industry workforce.

As an example, at a recent city forum, Dr Sandy Scott, director general of the Chartered Insurance Institute (CII) and Derek Wanless, chairman of the FSNTO, shared the speakers' platform. They showed how an independent body would be dovetailing with an organisation which will be one of the major forces in assisting GISC members to achieve the required T&C standards.

Setting down objectives
With this industry-wide responsibility, the FSNTO has commissioned a group of experts to design a T&C framework kit for the GISC, which may be used by its members and by training specialists to create a uniform foundation for moving forward and a common language for all to use.

The framework should allow those transacting similar types of business to communicate with each other, pool resources and customise a T&C scheme for an affinity group within the industry.

For larger organisations, it may be a question of devising a range of schemes to match the different levels of competence that might be required for different parts of the group.

The key objective of the FSNTO is that, having studied the framework kit, you will be able to look at your own organisation (or if you are a consultant, your client's organisation) and break down the structure and method of operation into the component parts necessary to begin designing a T&C scheme.

Additionally, it will assist you in measuring what your staff can do now, defining what you want to be able to demonstrate to the regulator and how to go about recording information and results. Identifying what you want a customer to feel about an organisation that they might not currently feel is the final stage.

A lot of work has gone into the style and content of the framework so that it is readable, understandable, creates a reasonably universal framework and conveys the underlying objectives of regulation.

Much of my work over the past 15 years has been involved with the process of disciplinary matters for regulators and advising the courts, the legal profession and the industry on expected standards of good market practice and competence. The burning question that I have encountered throughout the country, in speaking to organisations large and small, is: “Where do we start?”

What's included?
The framework kit helps the individual company to tailor employee training to their own requirements. It includes a brief background to regulation, how to plan the T&C scheme and key components, ideas, actions lists, flow charts for assessment, a path for product training design and the GISC rules and guidance.

It's important to remember that the whole process of regulation is about the adoption of good business practices and that a well disciplined T&C scheme is about doing more sustainable business.

Cost is a major factor that concerns the smaller GISC members in particular. The framework contains a guide to analysing the cost of each component.

Perhaps a more important factor is GISC's support for the notion of larger and more affluent members providing training assistance to agents and independent intermediaries. This was almost outlawed by the original regulators under the Financial Services Act, but the GISC accreditation process will allow its smaller members to tap into the network of training programmes that are being developed by some of the major organisations.

There has been a lot of press commentary about the notion that GISC is a club to be run for and by the major insurers at the expense of the smaller and independent organisations. All I see at present is a reasonably unflappable regulator working with the whole of the industry and major insurers, brokers and trade associations working to provide a universal T&C culture for all to buy into if they want.

The use of some form of framework, however, is going to be inescapable.

Methods of communication
Historically, works of this nature have been true text books. One of our key objectives was to create a work that could be read and understood across an industry that might include well over a million practitioners.

Most of us in the industry are not academics. We tend to be people-focused and, to that end, the framework is about breaking a complicated subject into manageable “bits” and using lists, short text boxes and images to convey important points.

This style has been well researched and discussed with a focus group that includes a broad range of training and compliance experts from across the industry.

Cooling off
Ultimately, the FSNTO-GISC framework kit is about the communication of a concept and ideas that will assist a GISC member to start designing a scheme to fit its own requirements. It is a starting point for a process that will develop, change and mature over the next few years.

More than anything, it is a document that is designed to unlock the mystery of T&C within a regulatory environment and the disciplines involved are actually good for business.

From the framework kit will flow more detailed guidance that will focus on more specific areas of the general insurance industry.

For more information or to order a copy of the framework, please contact Vicky Robinson on 020 7260 3742 or email

  • Robin Wood ACII is a consultant for the FSNTO.