I don’t know about you, but I always take the Roller when I am out for a spot of looting. You can get more stuff in the boot*.
Oh, hold on. You don’t suppose it could have been stolen, do you?
*Joel: this is proper English for “trunk” (which cars don’t have, only elephants do)
FCA has published final guidance on the approach firms should take to assess whether certain insurance products are still delivering full value to customers – and the measures that should be considered if not, including a return of premium. Obviously this is mainly aimed at insurers but could affect brokers where they are deemed to be the manufacturer of the product under the Product Oversight and Governance (POG) rules. That is unlikely to be the case in most London market business as the POG rules do not apply to large commercial risks and in a major triumph for your Trade Association about four years ago we got EIOPA to agree that the intermediary would never be deemed to be the manufacturer on subscription business.
That said it is probably worth availing yourselves of the gist of the new guidance, which is that firms:
- should consider the value of products where, due to the impact of coronavirus, there has been a material reduction in risk so that they are providing little or no utility to customers, and not just where claims are no longer possible;
- are not expected under this guidance to assess value on an individual customer level, but should consider FCA guidance on helping customers in temporary financial difficulty as a result of coronavirus; and
- can assess the longer-term impacts of coronavirus on their insurance products on an ongoing basis beyond the 6-month period the FCA has set out for product reviews resulting from this guidance.
In order to allow firms time to assess the full impact of coronavirus, FCA has allowed up until 3 December for these assessments to be carried out. Which is an insight into how long the Sages of Stratford seem to expect us to be cooped up for…
Fox in the box
They say that if you could choose to come back as anything in another life, you should come back as an Englishman’s dog. And this message certainly seems to be getting through to the urban fox collective who obviously see the key, the secret to a better life to be domestication. Urban foxes have reshaped snouts that allow them to better forage for food in their built up environment – and presumably are better shaped for scooping babies out of untended cribs. But part of this story really doesn’t add up. In order to opt for a life where you wake up only to place yourself behind your owner on video conferences and produce a cacophony of snoring, wake merely to demand a significant proportion of any meal consumed by said owner and, bizarrely, the froth off the cappuccino that Mrs C has made in the excellent new Nespresso machine (best Xmas present ever, yay me, let’s keep quiet about it being half price on Amazon), be taken on joyous walks across the countryside of the Garden of England before returning to somewhat tersely demand your own actual food before settling down to interrupt Netflix with yet more snoring before retiring to your ridiculously pampered sleeping quarters to get enough rest to be able to face it all again the next day, taking that option apparently requires decreased brain size. Surely not? It seems such a hound decision making process.
Andrew: the talks Failey
Firstly news that the Guardian has finally caught up with what we have been saying here for weeks. Covid-19 will be used to disguise the impact of a no deal Brexit and allow the fundamentalists in Downing St to actively pursue that as an outcome. And the thought must also dawned on somnambulant former FCA chief Andrew Bailey who, in a rare waking moment in a meeting with banks on Tuesday, urged them to up their no deal planning.
All of which makes little practical difference for LIIBA members as the reverse branch model is likely to be the only route to EU markets deal or no deal. But it is worth bearing in mind when working with clients who really now should focus on mitigating the risks no deal might pose to their business.
Speaking of sleeping beauty. Well not beauty. Well, let’s leave it and turn our attentions to Belarus where the masses are taking to the streets waving slippers to protest against the government of President Alexander Lukashenko and seek to ensure he is challenged in the upcoming elections. Now, there is no doubting that Lucky Lukashenko and his stark staring mad “let them drink vodka” approach to the Rona has been somewhat idiosyncratic. Although, to be fair, as we have seen from multiple surveys, it is guidance the people of Britain have readily followed. But, if I was hell bent on stamping on a cockroach, I would opt for sturdier footwear than a pair of slippers? This smacks to me of half hearted political protesting by people unwilling to brandish a proper pair of Dr Martens. And it is this lack of resolve that must surely be the downfall of the movement and see Lucky survive. After all, Belarus only has 44,255 confirmed cases of Covid-19 and 243 deaths. With the emphasis on the “confirmed”.
Still the whole merry episode does provide an excuse to remind ourselves of the time when Sacha Baron Cohen was still funny (which, irritatingly, coincided with the period when my friend Jim directed most of his stuff) and Ali G pitching his new business idea to the great American economist John Kenneth Galbraith.
I am off ram raiding in my Bentley.