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					The response by the
Chartered Insurance
     Institute
 to HM Treasury’s
  Consultation on
Regulating Insurance
     Mediation

     January 2003
Contents
Section                                                            Page

1.   Introduction                                                  3
2.   Summary of the CII’s response to the Consultation Document    4
3.   Detailed responses                                            9
4.   Other comments on the Consultation Document                   15

Appendix 1. About the CII                                          16
Appendix 2. About ed.                                              19




                         The Chartered Insurance Institute
                                20 Aldermanbury
                              London EC2V 7HY

                                Tel: 020 8989 8464
                                web: www.cii.co.uk




                                         2

                    Chartered Insurance Institute – January 2003
1.       Introduction
The Chartered Insurance Institute (CII) is the largest professional and educational
organisation in the global insurance and financial services sector.

This paper sets out the CII’s views in response to HM Treasury’s Consultation
Document on Regulating Insurance Mediation.


Introduction to the CII

        66,500 members
        Represented in over 120 countries
        Affiliated with over 60 institutes worldwide
        In 2002 ran 100,000 examinations
        70 examination centres in the UK and over 100 examination centres
         overseas.

Information about the CII and its financial services arm SOFA (the Society of
Financial Advisers) is set out in Appendix 1.

As well as examinations, the CII is committed to maintaining and enhancing the
competence of its members, backed by its work on ethics and a well-established
disciplinary system.

The CII has recently launched the UK’s first electronic total education system for
insurance and financial services called ed. We believe that this is of particular
importance to what the FSA is consulting on, as it is a cost-effective and easily
deliverable solution to life-long learning. Further information on ed. is detailed in
Appendix 2.




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                     Chartered Insurance Institute – January 2003
Summary of the CII's response to HM Treasury’s
Regulating Insurance Mediation Consultation Document

Overview of the issues:

The CII believes that there are a number of issues that need to be addressed in the
insurance sector that lead to poor image, and more importantly customers being
disadvantaged at point of sale or even worse at point of claim:

       Inadequate product knowledge and advice in the high street and retail
        outlets
       Unregulated environment for certain classes of insurance
       Concentration on sales process with little regard for administration and
        claims management
       Poor level of consumer knowledge regarding the nature of insurance

Proposed solution:

The CII believes that, from October 2004, insurance mediation should adopt a tiered
approach to the provision and administration of insurance products.

We also believe that all insurance products should be included within this regime,
such that consumers can be confident that they are receiving a minimum threshold
of technical knowledge and advice when purchasing any form of insurance.

The introduction of a simple badging of qualification in the general insurance
market would support the FSA's objectives for consumer protection, education
and trust in financial services. It would underpin the FSA's objective to
maintain market confidence.

(This is set out in Figure 1 over the page)

Core consideration to determine how insurance should be regulated

In determining how contracts of insurance should be regulated, the CII believes that
a core consideration should be applied regardless of the originator or distributor of
that insurance.

       regulation should depend on the relative risk and value to consumers




                                              4

                     Chartered Insurance Institute – January 2003
Figure 1. Insurance mediation and product sales hierarchy




   Complex Commercial                              Chartered Insurance Broker
 Insurances & Reinsurance




                                                      Qualified Intermediary




     “Simple” Products                              Competent Sales Person
    eg. Travel, Warranty




    Complexity of advice                            Hierarchy of competence
Core consideration to determine how insurance should be regulated             Cont/...

In addition to the regulation of all types of insurance by the FSA, the CII believes
that certain core principles should apply to all insurance transactions regardless of
the originator or distributor of that insurance. The core principles are:

   1. consumer protection should be consistent

   2. regulation, training and competence should apply regardless of whether a
      product is sold on a stand alone basis or part of a package

   3. all persons involved in a role that could have a direct financial impact on the
      customer (taking into account the nature of the business being transacted)
      should be able to demonstrate a minimum level of competence.

        We envisage, for example, that this would include:

              Sales people (including high street shop assistants)
              Advisors (including telesales)
              Claims handlers
              Underwriters
              Loss assessors
              Third party administrators

   4. training and competence should be proportionate and consistent

   5. training and competence needs to be demonstrated through an appropriate
      regime of assessment and qualifications

   6. regulation should be centralised and not devolved to any self regulated body

Immediate implications to our current regime

Application of our core consideration and core principle would mean that certain
types/sales of insurance which currently fall outside regulation would need to be
regulated. Specifically:

       Travel insurance sales, particularly package travel insurance sales
       All warranty insurance sales
       Payment protection insurance




Proposed future framework for training and competence

In order to ensure an appropriate level of consumer protection without affecting the
cost to the buyer we believe that three categories of competence should be
introduced.
                                           6

                     Chartered Insurance Institute – January 2003
         Intermediary                   Insurer                     Others
                                                        (eg Third Party Administrators)


  Chartered Insurance Broker       Chartered Insurer    Chartered Insurance Practitioner


      Qualified Insurance           Qualified Insurer   Qualified Insurance Practitioner
        Intermediary


   Competent Sales Person              Competent        Competent Insurance Practitioner
                                        Insurer

Chartered Insurance Broker / Insurer / Insurance Practitioner

This individual will hold a Chartered title (eg Chartered Insurance Broker), be
professionally qualified and be subject to the additional training, competence, ethical
and disciplinary requirements of their professional body.

We would envisage this qualification being limited to the highest echelons of the
insurance industry. Typically, a Chartered Insurance Broker would be best placed
to handle complex commercial contracts, possibly nationally or internationally.

Qualified Intermediary / Insurer / Practitioner

At the next level will be the qualified intermediary. This individual will also have
studied for a professional qualification and will differentiate themselves from the
competent sales person by the examinations that they have passed and also by
voluntarily taking on the training and competence requirements laid down by their
professional body. We would envisage here the individual would hold a designation
to assist in recognition by the public.

By way of example, training and competence would be appropriate for those staff in
high street intermediaries who handle commercial and personal lines business.

Competent Sales Person / Insurer / Practitioner

The competent sales person will be someone who has met the FSA’s basic
requirements for the job that they are doing. This group will also include individuals
who will go on to study for the higher levels of intermediary qualification.

We would envisage that sales advisers in call centres, travel agents and sellers of
personal products such as high street retailers would follow the competent
intermediary route. We would envisage here that the individual would work
towards a recognised professional insurance qualification included in the National
Qualifications Framework and would receive an appropriate designation.

The CII believes full statutory regulation of insurance intermediation from October
2004 will help formalise the intermediation structure and help boost public
confidence in it.

                                              7

                        Chartered Insurance Institute – January 2003
The introduction of a simple badging of qualification in the general insurance
market would support the FSA's objectives for consumer protection, education
and trust in financial services. It would underpin the FSA's objective to
maintain market confidence.

Commitment to Training and Competence Works

A clear demonstration of this approach working in practice was witnessed when
Lloyd’s tackled the problems it had in the 1990s by requiring new underwriters to
hold an ACII (Associate of the Chartered Insurance Institute) qualification or
equivalent. This helped both to raise standards and rebuild confidence in Lloyd’s.




                                         8

                    Chartered Insurance Institute – January 2003
Detailed responses

Our detailed responses to the Consultation Document are set out below. We have
adopted the order set out in Annex A – Summary of Issues for Feedback (The issues
detailed by HM Treasury are shown in italics, with our response in normal type.)

What contracts of insurance will be regulated?

1.    The Government is seeking views on the scale of any problem with the sale of travel
     insurance sold as part of a package and on the proposed options. In particular, views are
     sought on:

        the factors to be taken into account in determining the nature and extent of
         regulation, including supporting evidence;

Core consideration to determine how insurance should be regulated

        regulation should depend on the relative risk and value to consumers

In addition to the regulation of all types of insurance by the FSA, the CII believes
that certain core principles should apply to all insurance transactions regardless of
the originator or distributor of that insurance. The core principles are:

        consumer protection should be consistent

        regulation, training and competence should apply regardless of whether a
         product is sold on a stand-alone basis or part of a package

        all persons involved in a role that could have a direct financial impact on the
         customer (taking into account the nature of the business being transacted)
         should be able to demonstrate a minimum level of competence.

         We envisage, for example, that this would include:
            Sales people (including high street sales people)
            Advisors (including telesales)
            Claims handlers
            Underwriters
            Loss assessors
            Third party administrators

        training and competence should be proportionate and consistent

      regulation should be centralised and not devolved to any self regulated body

        the scale and nature of consumer detriment in relation to travel insurance sold as part
         of a package;


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                       Chartered Insurance Institute – January 2003
The exact number of complaints that specifically relate to policies sold as part of a
package is unknown. However, it is fair to conclude that they represent a
considerable number, as travel insurance is among the top 10 subjects for complaint
received by the Financial Ombudsman (Source: Financial Ombudsman Service
annual report 2001/2002).

Our concern is that sales persons may often be pressured into selling insurance
within a package on terms that are significantly worse than could be obtained on the
open market. At the same time, consumers may be disinclined to shop around
because, relative to their total spend, the cost of insurance is perceived to be
'incidental', in the same way as, for example, airport taxes.

We are not advocating that the sale of insurance be restricted to certain types of
distributor - apart from anything else, this would be impractical given the size and
nature of the market. What is more, travel insurance is often sold as part of a
package with other insurance products such as life insurance or private medical
insurance, and there would be added complexity if mandatory regulation were
brought in.

What is crucial is that there should be differentiation between the codes and rules
adopted by Designated Professional Bodies (DPBs) and those adopted by trade
bodies. We are comfortable with the former, but we believe that the public interest is
jeopardised by the potential conflicts of interest inherent in the codes of trade bodies,
especially within a statutory regulation framework.

      which of the three options outlined in Para 2.4. is most appropriate in terms of
       balancing consumer protection against industry costs and competition;

The most appropriate option, in our view, is the second option (FSA regulation).
Intellectually, it is difficult to argue for travel insurance to be regarded as
fundamentally ‘different’ to all other types of insurance.

No statutory regulation is a poor option because it would leave consumers with less
protection in an area where claims, if they occur, can be very significant both in
financial terms and practically.

Industry specific regulation would be divisive, create a dangerous precedent and
potentially confuse the consumer.

      any other relevant considerations;

A further issue is that, if industry specific regulation were to be adopted, how far
should the term ‘travel insurance’ be defined? For example if a typical travel
insurance policy included say £10,000 of personal accident benefits, but a particular
travel agent sold a higher cost policy with £100,000 of personal accident benefits
should that still just be covered by the ABTA Code? If the accidental death benefit
applied all year round, not just while the individual was abroad and other benefits
were added, so that in effect the travel insurance became only a small part of the
insurance ‘package’, would the ABTA Code be sufficient then? If not, at what precise
point would the situation change?

                                             10

                     Chartered Insurance Institute – January 2003
The danger of allowing regulatory arbitrage is one that could become a significant
issue if industry specific regulation were to be accepted for travel insurance. An
insurance contract is an insurance contract and there should not be exceptions in its
regulation.

        whether there are any other options that should be considered? (Para 2.10)

No. For simplicity and consumer and industry confidence the regulation should rest
with the FSA.

2.    Should all motor warranties which are contracts of insurance be subject to regulation by
     the FSA or only those costing more than €500 Euros (about £300) per annum? (Para
     2.15.)

Yes. For the same reasons that all travel insurance should be regulated by the FSA.

3.    Are there other factors which the Government should take into account in considering
     regulation of extended warranties on domestic appliances or other goods? (Para 2.17.)

To apply an arbitrary limit would cause problems where the relationship between
the Pound and the Euro changed, would be confusing to consumers and could
encourage disreputable firms to offer products at a price just under the exemption
threshold so as to avoid regulation.

The regulation should take into account the need for appropriate training and
competence which would include ensuring those advising or selling insurance
products are competent to do so.

Which activities will be regulated?

4. Are there other activities in relation to work preparatory to the conclusion of contracts of
   insurance that should be regulated? (Para 3.7.)

The issue is whether the consumer is given information or advice. In general,
information need not be regulated (under insurance mediation rules). However, we
believe that advice always should be. Clear guidelines on training and competence in
the General Insurance market would help clarify this and raise standards.

5. Do you agree that claims handling by intermediaries on behalf of insurance companies,
   expert appraisal and loss adjusting should not be subject to direct FSA regulation? If not,
   do you have evidence of consumer detriment that would warrant such regu lation? (Para
   3.13.)

A claim is the single most important example of performance under a policy of
insurance. Therefore, firms should apply the highest standards on claims and it is
sound business sense for them to do so. For example, an insurer should ensure that
an appropriate training and competence regime is in place and that relevant
qualifications are held by those in supervisory or overseeing roles.

All claims handlers should be competent, remain competent and be appropriately
supervised. Insurers and claims handling organisations including third party
                                              11

                       Chartered Insurance Institute – January 2003
administrators need to have systems in place to ensure that happens and for
competence to be evidenced. The CII has led the financial services industry in the
development of its electronic total education system which provides a cost effective
solution to maintaining the competence of claims handlers. Again, we would see
appropriately awarded qualifications and designations helping the public understand
the competence and level of person they are dealing with in the industry.

Anyone or any firm that provides a service to a claimant that may involve giving
advice to that claimant should be regulated. That would include loss assessors, for
example and third party administrators. If, for example, third party administration
were to fall outside regulation then insurers may move towards using such services
purely to avoid regulation. That would not be in consumers’ best interests. It is
important to note too, that even where a third party administration service is used,
the principal (the insurer) is still responsible for all actions of the third party. We
believe that it would be useful for the FSA to remind firms of this responsibility.

In the event of a disputed claim, any individual or firm that advises a claimant should
be regulated by the FSA. This would include lawyers, perhaps regulated by their
designated professional body rather than by the FSA itself.


6.    Do you agree that the financial promotion regime should not apply to promotions of
     general insurance mediation activities? Is there sufficient consumer detriment to justify
     bringing insurance mediation activities into the Financial Promotion Order with the
     broad Part V exemptions applying? (Para 3.25.)

Consumers should understand whether an intermediary is professionally qualified,
their status and what products and services they offer. We note that the FSA’s
position is to allow consumers to ask for commission details. This obviates the need
to require commission to be disclosed.




7. Should the exclusion for information provided on an incidental basis in the context of
   another professional activity apply to 'qualifying contracts' of long-term insurance?
   Would this be likely to cause significant consumer detriment and if so, how? (Para 3.27.)

We think that this issue should be subject to further public consultation.

8. Should the regulatory regime be extended to mediation activities in relation to rights to
   and interest in, all contracts of insurance? (Para 3.29.)

Yes. To prevent consumer detriment from arising in situations where policies are
sold on (for whatever reason) the regulatory regime should be extended to mediation
activities in relation to rights to and interest in, all contracts of insurance.

Who will be regulated and how?




                                               12

                       Chartered Insurance Institute – January 2003
9. Do you agree that the appointed representative’s regime should be extended to insurance
   mediation activities? Would this cause significant consumer detriment and if so, how?
   (Para 4.7.)

Yes. Appointed representatives should be subject to an appropriate training and
competence regime. This could be delivered through the CII’s e-learning ed. system
and the availability of appropriate and publically recognised levels of qualifications.

10. Should the provision of information exclusion also cover advice? Would this cause
    significant consumer detriment? (Para 4.10.)

We agree with the Government’s view on this. Anyone giving advice on insurance
should be regulated.

11. Do you agree that the FSMA Part XX regime for Designated Professional Bodies
    should apply to insurance mediation activities? Would this cause significant consumer
    detriment and if so, how? (Para 4.11.)

We believe that the key issues are:

    -   there should be a level playing field. Regulatory standards should not be
        compromised just because an individual is a part-time, rather than full time,
        insurance salesperson. An analogy may be drawn with surgeons. It would not
        be prudent to apply the test of a lower standard of care where a surgeon did
        not hold a full time NHS contract for example.
        One exception might be where a professional person is providing advice to a
        claimant on a disputed insurance claim. Here, it may be most efficient, in
        practical terms, for the professional person to be regulated by a designated
        professional body. This is because the professional person does not derive
        any direct income from the sale of a policy of insurance. Where, however,
        they do derive an income, FSA regulation should apply. In practice,
        regulatory authority could be delegated by the FSA, but it should apply on
        exactly the same terms as the FSA would itself apply directly.

    -   competence. This issue may best be addressed in the FSA’s consultation
        process regarding training and competence generally.

12. Do you agree that the limitations that currently apply to the advice that a professional
    can give under Part XX in relation to long term contracts of insurance should not apply
    to advice given in relation to general insurance? (Para 4.12.)

Yes. This is acceptable because existing designated professional bodies have strict
professional and ethical codes. On those grounds only, is this acceptable. We are
concerned that, in other situations, consumer detriment could arise, especially as the
term ‘general insurance’ could extend to a range of currently unregulated products
which are not themselves general insurance, e.g. long term care insurance.

What will the requirements of regulation be?




                                             13

                      Chartered Insurance Institute – January 2003
13. Do you agree that the notification requirements for the controller's regime for general
    insurance intermediaries should be streamlined as outlined in Para 5.14. above? Would
    this cause significant consumer detriment and if so, how? (Para 5.14.)

We agree, so long as supplementary activities do not become the major element of
an individual’s or firm’s business.

Regulatory Impact Assessment

14. The Government would welcome views on the assumptions made in the Regulatory
    Impact Assessment. It would be helpful to receive views on both the costs and benefits to
    businesses and consumers of the proposed regulation. We would particularly like to
    receive views on the likely impact on the small firms that will be covered by FSA
    regulation of general insurance mediation.

We would draw attention to the work of the National Consumer Council on
consumer impact assessments. The CII is a professional body rather than a trade
association and has a unique membership base. We would be happy to work with the
FSA to source the views of our practising members on the issues raised.




                                              14

                       Chartered Insurance Institute – January 2003
4. Other comments on the Consultation Document
The CII believes that to achieve the desired aims of regulation, it is important for the
regulator to apply the overriding principle of having a level playing field. In
addition, we believe it is important, both for consumers and for the long term
viability of the insurance industry, for standards to be raised. We also believe a
suitable training and competence regime should be applied across insurance based on
a blend of qualification and assessment, and the awarding of easily identifiable and
'trusted' badges/designations that are recognised by the consumer.

A key issue to be addressed is that insurance products are marketed and sold
through a wide range of distribution channels with many products sold by
individuals and firms for whom the selling of insurance is subsidiary to their main
business. There are concerns that regulation should not be so onerous as to
effectively stop insurance being sold through such channels. However, whilst we
would agree with these concerns, the regulatory requirements should not apply in
such as way as to reward the lowest common denominator at the expense of
consumer protection.

There is no fundamental conflict in these ideals and we believe strongly that all
these aims are achievable through a blend of qualifications or assessment relevant to
the risk for consumer detriment in order to produce better informed and competent
advisers to the public.

The CII sees its role as protecting the public by guiding the profession and, working
with various partners, we have developed an industry wide process that adopts
modern technology to deliver the solutions that make these ideals possible.

The Internet is the medium which makes this possible and the CII’s ed. system is the
mechanism that can deliver it. ed. has been developed to allow both firms and
individuals to meet regulatory requirements regarding learning and competence
simply, effectively and at low cost.

The ed. system continues to be developed to meet our customers’ and partners’
needs and we aim to continue to offer appropriate examinations and assessments to
meet both the needs of our customers and of the regulator.

We therefore look forward to working closely with the FSA to develop solutions to
make the new regulatory system from 2004 both workable and fair.




Appendix 1


                                          15

                     Chartered Insurance Institute – January 2003
About the CII
The Chartered Insurance Institute (CII) was established in London in 1897. Today it
has expanded to embrace all aspects of insurance and financial services and has over
66,500 members in over 120 countries worldwide. Around 10% of its membership is
based outside the UK and it is the largest professional body in insurance and
financial services in the world. It gained Chartered professional body status in 1912.

The CII is run by its members for the benefit of its members, their employers and
the industry sector it operates in. A permanent staff of over 150 administers the
organisation, along with hundreds of largely unpaid volunteer members. The CII
has headquarters in the City of London with a customer service contact centre in
South Woodford, London.

CII examinations are currently sat in over 100 examination centres worldwide and
in 70 examination centres in the UK. Other countries adopt elements of the CII’s
examinations or skills in their own examination systems. Globally, the CII’s breadth
is rivalled only by the US based CPCU, although that organisation only covers
property and casualty (general) insurance.

The CII has:

      68 local institutes in the UK (including Jersey, Guernsey and the Isle of Man)
      7 associated institutes in Ireland (part of the autonomous Insurance Institute
       of Ireland)
      69 affiliated institutes worldwide (these are not part of the CII but affiliated
       to it)
      developed the opportunity for (usually larger) employers to offer in-house
       examination centres for such examinations as FPC.

The Society of Financial Advisers (SOFA) is the financial services arm of the CII.
Established in 1991, it has almost 10,000 members, most of whom are involved in
investment advice. It has more practitioner members qualified to a professional level
than any other membership body within retail financial services.

We have worked with UK regulators for many years, including the SIB, LAUTRO,
FIMBRA, IMRO, PIA, and now MCCB, GISC, Lloyd’s and the FSA.

The CII offers a wide range of examinations and professional qualifications
including:

   -   Fellowship of the CII (FCII): ACII plus three years’ CPD, completion of a
       major project and passing a business ethics programme module

   -   Associateship of the CII (ACII): 10 examinations (from a menu of 31 ACII
       subjects). The ACII is the industry flagship professional qualification and
       equates to degree standard

   -   Chartered title: FCIIs and ACIIs may apply to be a Chartered Insurer,
       Insurance Practitioner or Broker (depending on their job). Chartered status


                                         16

                    Chartered Insurance Institute – January 2003
       includes a commitment to continuing professional development (CPD) and to
       a disciplinary regime and codes of conduct and ethics

   -   Certificate of Insurance Practice: five examinations from a menu of 29
       technician level qualifications giving MSTI (Membership of the Society of
       Technicians in Insurance)

   -   Certificate in IT for Insurance Professionals (one examination), targeted at
       those in IT in financial services and jointly awarded with the British
       Computer Society

   -   Insurance Foundation Certificate (two examinations): basic competence level
       qualification, aimed at everyone in the insurance and financial services sector

   -   Foundation Insurance Test (one examination): foundation qualification on
       entry to the industry

   -   Financial Administration Foundation Certificate (FAFC): foundation
       qualification for those in life and pensions administration

   -   Advanced Financial Planning Certificate: professional level qualification for
       financial advisers. Members may go on to become Associates or Fellows of
       the Society of Financial Advisers

   -   Financial Planning Certificate: the benchmark qualification for financial
       advisers recognised by the FSA

   -   Mortgage Advice Qualification (MAQ): one examination for mortgage
       advisers which, together with the attainment of the FPC will satisfy the
       Mortgage Code Compliance Board (MCCB) examination requirement for
       registration

   -   International Certificate for Financial Advisers: one examination, targeted at
       non-UK based financial advisers

   -   Life and Pensions Foundation Certificate: FP1 and FP2.



As a global professional and examinations body, the CII operates examination
centres in over 100 countries worldwide. It has negotiated a number of special
agreements with bodies worldwide that use CII expertise to a greater or lesser
extent. It has mutual recognition arrangements with a number of countries,
including for example, the USA, Canada and Germany. It is also part of the process
that is seeking to develop common and transferable standards, through its
chairmanship of the Institute for Global Insurance Education and the European
Financial Planning Association.

In addition, the Institute has worked with numerous countries to establish
qualifications based on CII syllabuses and tutor materials, localised to the law and
practice of the CII partner country.
                                         17

                    Chartered Insurance Institute – January 2003
Appendix 2

About ed.
ed. is a way of acquiring knowledge and achieving regulatory compliance via
electronic communications. It harnesses the power and reach of the internet to
revolutionise the whole process of education and continuing professional
development.

The CII has expanded the range and scope of traditional online learning with the
launch of ed. Designed for the full spectrum of general insurance and financial
services organisations, it provides training on a wide range of subjects and addresses
regulatory compliance and competence issues.

ed. gives organisations control over the learning and competency activities of their
workforce. It increases the potential for enhanced learning, examination success and
regulatory compliance by providing candidates with comprehensive, relevant, up-to-
date information via a flexible, responsive communications facility.

ed.: core elements

Learning Management System (LMS)
The Learning Management System within ed. provides employees at all levels of the
insurance and financial services industry with access to the CII’s portfolio of training
material. Thus, a large amount of information has been distilled into a series of
interactive tutorials which can be selected to suit the needs and objectives of the
employer and the employee.

The LMS’s powerful database-driven system, which holds the training material,
student records and system operation protocols, can be used by the employer to
track the training and development activity of every employee, ensuring that
efficiency and effectiveness are maximised.

Compliance and Competency System (CCS)
The Compliance and Competency System has been designed following extensive
consultation with leading general insurance and financial services organisations and
currently provides support and guidance for those seeking to comply with the
competency and training rules of the General Insurance Standards Council and th e
Financial Services Authority.

The core GISC/FSA compliance tools are underpinned by a comprehensive,
coordinated range of supporting service including a ‘Knowledge Assessment
System’, ‘Continuing Professional Development Log’ and a ‘Reporting System’.

At the CII we recognise that organisations have their own specific requirements, and
so CCS has been developed to cater for the introduction of bespoke features and
content alongside the universal core material. This means that companies can obtain
a system which reflects their particular circumstances and which is capable of
changing as the organisation grows and the regulatory context develops.

                                          18

                     Chartered Insurance Institute – January 2003
ed.: meeting your needs

By improving management controls and better equipping students to achieve
learning success, ed. can play a pivotal role in developing the capabilities of the
business as a whole.

ed. is cost effective. It makes more efficient use of employee time and ensures that
resources are precisely targeted to meet the objectives of both employer and
employee. Administration is simplified or in many instances eliminated.

ed. is fit for the market because it has been developed in response to customer
demands for more and better computer-based training and support. And in tracking
the very latest regulatory training and competence requirements, it will help
companies ensure they are fit for business.

Details of ed. can be found at www.ed.cii.co.uk




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                     Chartered Insurance Institute – January 2003

				
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