Sensible, affordable and justifiable. It's hard to argue with the verdict passed this week on the GISC's proposed rulebook by Biba's chief executive, and firmly seconded by the AIIB's chairman.
Of course, both Mike Williams and Mike Slack have been deeply involved in shaping the framework for general insurance's new regulatory regime. But their approval for the anxiously awaited guidelines is certainly not a question of self-congratulation: what has been produced by Chris Woodburn and his council is a document that holds no fears for anyone who takes pride in plying his trade professionally.
Over and beyond that, the GISC's proposals offer the industry a chance to create a new environment of common training and trading standards that will improve every channel of distribution and delivery. In that way, the consumer benefits – which was always the GISC's raison d'etre. But so, as a result, does the industry.
The beauty of it for brokers and most intermediaries is that this goal should not prove difficult to attain. The new guidelines are solidly rooted in current IBRC and ABI practices. And where they go further than presently required – such as with enhanced PI cover, or new audit requirements – the best are already operating to these standards.
Undoubtedly there will be some firms that find the transition to modern and progressive regulation a shock to the system – both financially as well as operationally. But in an era of transparency and customer protection, there can be no place for individuals not prepared to embrace best business practice in every aspect of their operations.
Not every broker and intermediary always has his sights fixed on these higher aspirations of total consumer satisfaction. The costs of regulation grip them far more firmly. Happily for the majority, the costs of this regime fall lightly on their shoulders. For small brokers, the costs of GISC will be almost identical to those under IBRC – intentionally, no doubt: it would have been madness to alienate the bedrock of the sector.
Mid-to-large brokers may pay a little more. And the largest brokers will certainly pay a lot more – unless they are a Lloyd's broker, in which case they are more than quids in.
The levy on insurers may favour the larger ones disproportionately, which could cause difficulties if it means small motor insurers, for example, are disadvantaged. Undoubtedly, there are some areas where more detail is required from the GISC.
But at this stage, Woodburn and his team can afford to draw breath and congratulate themselves on all they have achieved. Constructing a new regime from scratch and at speed was a formidable task. They have gone a long way to pulling it off. The industry owes them its gratitude.