INSURANCE REGULATORY ADVISORY

FCA Compliance for MGAs, Insurance Brokers & Intermediaries

Senior regulatory support for insurance businesses across ongoing FCA compliance, product governance, distribution oversight, Consumer Duty, compliance audits and regulatory remediation.

We work alongside compliance teams and senior management to identify regulatory gaps, strengthen existing arrangements and provide additional specialist capacity where required.

MGAs

Product governance, delegated authority and distribution oversight.

Insurance Brokers

ICOBS, Consumer Duty, governance and ongoing compliance.

Principal Firms

Appointed representative governance and monitoring.

Regulatory Reviews

Independent assurance, FCA readiness and remediation.

CAPABILITIES

How We Support Insurance Firms

Ongoing FCA Compliance Support

Compliance monitoring, policies, governance, regulatory change, board reporting and senior advisory support for firms that need additional technical capacity.

MGA Compliance

Support for MGAs operating within delegated authority structures, including product governance, distribution arrangements, broker relationships, compliance monitoring and regulatory governance.

Insurance Broker Compliance

Practical compliance support for brokers covering conduct requirements, customer outcomes, governance, product distribution, Consumer Duty and regulatory change.

Product Governance & PROD 4

Review and implementation of product governance arrangements including product approval, target markets, distribution strategy, product information exchange, monitoring and fair value requirements where applicable.

Delegated Authority & Distribution Oversight

Regulatory review of delegated authority arrangements, agency and broker frameworks, oversight processes, remuneration structures, distribution controls and governance.

Consumer Duty

Support across products and services, price and value, consumer understanding, consumer support, outcomes monitoring and governance.

Compliance Audits

Independent reviews against applicable FCA requirements with prioritised findings and practical remediation plans.

FCA Supervision & Remediation

Support with FCA enquiries, information requests, supervisory reviews, remediation programmes and preparation for more intensive regulatory scrutiny.

IN FOCUS

Support for MGAs and Delegated Authority Businesses

MGAs rarely sit in a single regulatory category. The same business can be exercising underwriting authority on behalf of an insurer, influencing product design, contracting with brokers and, in practice, shaping the outcomes experienced by the end customer.

That combination is where regulatory responsibility becomes contested. Firms are often clear about their commercial role and much less clear about where manufacturer obligations end, where distributor obligations begin and who is accountable for evidencing that the product continues to deliver fair value.

The output is not a policy library. It is a clear view of who is responsible for what, whether the evidence exists to demonstrate it, and what needs to change.

Where the regulatory pressure sits

  • /insurer capacity and the scope of the underwriting authority granted
  • /product design and the approval process behind it
  • /broker and intermediated distribution chains
  • /customer outcomes achieved through third parties
  • /delegated authority governance and reporting
  • /the allocation of regulatory responsibility between the parties

How we help

  • /reviewing regulatory responsibilities within delegated authority structures
  • /reviewing broker agency agreements and terms of business from a regulatory perspective
  • /clarifying product manufacturer versus distributor responsibilities
  • /target market definition and distribution strategy controls
  • /product information exchange between manufacturers and distributors
  • /remuneration and distribution arrangements, including fair value considerations
  • /compliance monitoring programmes proportionate to the delegated activity
  • /broker and coverholder oversight, including testing and file review
  • /governance, committee structures and management information
CLIENT TYPES

Who We Support

  • /managing general agents and managing general underwriters
  • /insurance brokers and intermediaries
  • /wholesale and specialty brokers
  • /coverholders operating under delegated authority
  • /principal firms with appointed representatives
  • /appointed representatives and introducer ARs
  • /insurance distributors and affinity partners
  • /firms arranging or advising on general insurance contracts

Requirements differ significantly depending on permissions, the firm's role in the distribution chain and whether it is acting as manufacturer, co-manufacturer or distributor. We scope each engagement to the firm's actual regulatory position.

HANDBOOK REFERENCES

Regulatory Framework

The requirements that apply depend on the firm's permissions and activities. The provisions most frequently in scope for insurance intermediaries and MGAs include the following.

ICOBS

Conduct of business requirements for insurance distribution, including disclosure, eligibility and claims handling expectations.

PROD 4

Product oversight and governance for insurance manufacturers and distributors, including target market, product approval and fair value.

Consumer Duty (PRIN 2A)

The cross-cutting rules and four outcomes, together with the associated monitoring and board reporting expectations.

Principles for Businesses

The overarching standards against which the FCA assesses conduct and governance.

SYSC

Systems and controls, governance arrangements, outsourcing and the compliance oversight function.

SM&CR

Senior manager responsibilities, certification and Conduct Rules as they apply to insurance intermediaries.

DISP

Complaints handling, root cause analysis and reporting.

SUP

Supervision, notifications and regulatory reporting obligations.

Appointed Representative requirements

Principal firm obligations for appointment, oversight, monitoring and notification.

WHEN FIRMS CALL US

Typical Reasons Insurance Firms Engage Us

the compliance function needs additional senior technical capacity

product governance and fair value evidence would not withstand FCA scrutiny

delegated authority arrangements have grown faster than the oversight around them

broker and coverholder monitoring is inconsistent or largely unevidenced

Consumer Duty work produced documents rather than outcome evidence

the firm has taken on appointed representatives and the oversight framework has not kept pace

an insurer audit or internal review has identified regulatory weaknesses

the FCA has asked questions and a structured, evidenced response is required

the board wants independent assurance before a transaction or capacity renewal

FREQUENTLY ASKED

Insurance, MGAs & Brokers Compliance FAQs

Yes. We support MGAs across product governance, delegated authority arrangements, broker and distribution oversight, Consumer Duty, compliance monitoring and regulatory governance. Work can be delivered as a defined project, a specific workstream or on an ongoing retained basis alongside the firm's existing compliance resource.

Scope is set against the firm's permissions and business model. A typical review covers governance and oversight arrangements, the compliance monitoring programme, product governance and fair value evidence, distribution and delegated authority controls, Consumer Duty outcomes and monitoring, complaints handling and root cause analysis, financial promotions, vulnerable customer arrangements and regulatory reporting. Findings are prioritised by regulatory risk with a practical remediation plan.

PROD 4 allocates obligations by role rather than by firm type. A firm that has a decision-making role in designing or significantly adapting a product will generally have manufacturer obligations, including product approval, target market definition and fair value assessment. Distributors have their own obligations covering distribution arrangements, the information they obtain and share, and ensuring distribution is consistent with the identified target market. Where an MGA and an insurer share design decisions, co-manufacturer arrangements need to be documented.

Yes. The common gap is not the absence of a policy but the absence of evidence. We support outcome testing, fair value assessment methodology, distribution chain value considerations, management information design, the annual board assessment and remediation where monitoring identifies poor outcomes.

Yes. We review agency agreements and terms of business from a regulatory perspective, assess how regulatory responsibility is allocated in practice, test the oversight and monitoring applied to coverholders and brokers, and review the management information used to demonstrate control.

We provide senior regulatory support alongside a firm's existing arrangements. We do not automatically assume the role of an internal compliance officer or a senior management function. Where a firm needs sustained capacity, retained support can be structured around scheduled input, technical escalation and specific workstreams.

Yes. We help management understand the regulatory issue behind the request, organise and test the underlying evidence, draft a clear and accurate response, and where required design and oversee a credible remediation programme with follow-up testing.

SPEAK TO OUR TEAM

Discuss your regulatory position

Tell us where the pressure is and we will tell you, candidly, what we would do about it. Initial discussions are free and without obligation.

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