As from 1 October 2018, new Designated Professional Body (DPB) rules apply. These rules should be read in conjunction with the 2018 DPB guidance.

All firms and professionals engaged in insurance distribution activities in the UK should read these rules and their accompanying guidance carefully. It is important to understand and have thorough, detailed knowledge of both documents.

There are a number of changes to the DPB rules and guidance you should be aware of if your firm is part of the DPB scheme.

The changes were approved by the Financial Conduct Authority (FCA) in July 2018 and reflect new obligations and requirements under the Insurance Distribution Directive (IDD), which replaces the Insurance Mediation Directive (IMD).

Please note that we have recently further clarified requirements in relation to the Insurance Product Information Document (IPID) for requirements for DPB firms. This is to clarify that commercial clients do not require an IPID. This clarification is made to better reflect the FCA requirements, however it does not mean that there should be a lower standard of information to commercial customers. The changes are made to provide greater flexibility to target and customise information for commercial clients. Commercial clients will still be required to receive appropriate product information.

Main changes

Increase in professional indemnity insurance (PII) cover

The minimum PII cover for DPB licensed firms has increased to €1.25m for single cases and €1.85m for the annual aggregate. This applies when the policy is taken out, renewed or extended.

New Insurance Product Information Document (IPID) requirements

DPB licensed firms are required to obtain and provide their customer clients with an IPID. An IPID must be produced by the manufacturer of the insurance product. The firm is required to issue the IPID together with the demands and needs statement (DNS) which must be presented to the client before the placement of the insurance. Whatever the proposed contract, under the IDD this must be consistent with the demands and needs indicated by the customer in its DNS.

Firms dealing with a commercial customer: 

• may choose to provide some of or all of the appropriate information in an IPID, a policy summary or a similar summary if it considers this to be a comprehensible form in which to provide that information; and
• should include the IPID information (regardless of whether an IPID itself is provided).

Professional training and development requirement

Although DPB licensed firms are not required to fulfil the 15-hour CPD requirement, due to their status of ancillary insurance intermediaries, in line with Rule 6 of the RICS Rules of Conduct for Firms, firms nevertheless need to ensure that relevant staff undertake professional training and development every year relating to insurance distribution activities. DPB licensed firms are required to confirm their compliance with these requirements annually and can be asked to provide evidence.

Cross-selling requirement

The new DPB rules provide that when an insurance product is complementing another good or service which is not insurance, as part of a package or as part of the same agreement to the same client, a DPB licensed firm must inform the client about the possibility of buying the different components separately. 

Furthermore, the obligation to inform clients about commission received still holds. Though this is not a new requirement in the rules, it is imperative that firms continue to account to clients for all fees, commission and other benefits obtained through general insurance distribution activity. The client must be informed in writing about the commission, which must be remitted to the client, and only if the client gives informed consent, in writing, allowing the firm to retain that amount of commission, can the firm keep the commission received.

Applications 

In order to join the RICS DPB scheme, you will need to have an RICS regulated firm.

If your firm is already regulated by RICS, you will need to complete the DPB Application and the Close Links Information.

If you need to register your firm, please go to the Firm Regulation page and follow the instructions. Once you have done this, you will need to complete the DPB Application and the Close Links Information.

At the application stage you will be requested to provide information on:

• training and development of relevant staff that relates to the undertaking of insurance distribution activities
• the good repute of the firm
• professional indemnity insurance cover
• client money protection
• information on holdings of shareholders, or close links, that could affect our supervisory functions.

email your application

Licensing

Once your application has been submitted, a caseworker will review your response to the questions. When the application has been approved an invoice will be issued for the application fee. When this has been paid a licence will be issued to you. You cannot rely on the licence until the fees have been paid.

If you wish to join the DPB scheme and are currently directly authorised by the FCA then you should begin the FCA cancellation process. Once this has been completed with the FCA , you can apply for a DPB licence.

Find out more about regulation