General Insurance Advice & Sales
Process
1.
2.
3.
4.
INTRODUCTION ........................................................................................................ 2
General Guidance ...................................................................................................... 2
Introducing ................................................................................................................. 2
ADVICE & SALES PROCESS ................................................................................... 3
Initial Disclosure Document (IDD) ............................................................................... 3
Fees and Commission Disclosure .............................................................................. 3
Fact find ..................................................................................................................... 4
Existing Plans ............................................................................................................. 4
Affordability................................................................................................................. 4
Suitability of Recommendation ................................................................................... 4
Research .................................................................................................................... 5
Product Disclosure ..................................................................................................... 5
Policy Summary ......................................................................................................... 5
Statement of Price ...................................................................................................... 6
Statement of Demands & Needs ................................................................................ 7
Cancellation Period .................................................................................................... 8
Claims Process .......................................................................................................... 9
Re-broking Insurance ............................................................................................... 10
Group Insurance Policies with Multiple Policyholders ............................................... 11
Product Disclosure on ‘Distance Contracts’ .............................................................. 11
Distance Contracts - Telephone ............................................................................... 12
RENEWALS AND MID-TERM CHANGES ............................................................... 13
Mid Term Changes ................................................................................................... 14
RECORD KEEPING REQUIREMENTS ................................................................... 14
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1.
INTRODUCTION
1.1
Statutory regulation of GI sales has been driven by the need to comply with the
Insurance Mediation Directive (IMD); plus other EU directives such as the Distance
Marketing Directive, Consolidated Life Directive, Third Non-Life Directive and Fourth
Motor Insurance Directive.
1.2
The New Insurance Conduct of Business Sourcebook (ICOBS) came into effect on
the 6th January 2008 with a six month transitional period that meant firms were
expected to meet the required standards by 6th July 2008.
1.3
The new ICOBS Sourcebook is a significant step forward in the FSA’s programme
of principles-based regulation with the removal of many detailed rules and a much
greater reliance on the FSA’s Principles for Business and a small number of highlevel standards expressed as rules.
1.4
The FSA has tried to impose the minimum regulatory burden necessary to
adequately protect consumers, and comply with the EU Directives. This handbook
has adopted these rules and largely relies on disclosure to deliver its objectives.
General Guidance
1.5
Under the ICOBS rules there is no specific ‘independence test’, unlike the mortgage
market. However the impression given to customers about the status of the firm
must be clear, fair and not misleading considering the firm’s adverts, website, shop
front etc. It is also misleading to suggest you can provide an independent
insurance service, unless you can offer a wide range of Insurers through the firm.
1.6
This manual applies to advisers who are permitted to give advice on protection and
‘other’ general insurance products.
1.7
A regulated general insurance product or ‘non-investment insurance contracts’ as
defined by the FSA includes:
 ‘Other’ General Insurance Products all general insurance such as
household, motor, pet and private medical, and
 Pure Protection Products which have no investment element, such as term
assurance, critical illness, income protection and PPI.
NB: Long term care insurance is covered by the FSA’s designated investment
regime – it is not considered to be an insurance product for regulatory purposes.
1.8
Advisers (you) are permitted to provide advice on all the above areas provided you
are deemed competent or are under supervision as outlined in your training record.
Refer to the Training and Competence Manual for further guidance.
Introducing
1.9
Unlike the situation applying to mortgages, there is no general exemption from
authorisation for introducing insurance. None of the existing exemptions in the
Regulated Activity Order apply, and the Insurance Mediation Directive prevents the
FSA from exempting introducing from the list of regulated insurance activities.
1.10
None of this prevents you from introducing types of insurance that you cant, or don’t
wish to sell yourself, however certain procedures must be followed:
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 Limit activities to putting customers in contact with a person who is
authorised to arrange insurance. This means you can’t get involved in filling
in application forms, factfinds etc;
 Disclose the receiving firm’s name, address, statutory status; details of any
fees that will be charged for the introduction service, whether the receiving
firm is part of the same group as [Firm Name] to the customer.
2.
ADVICE & SALES PROCESS
2.1
You must consider all products within your scope before making a recommendation.
However, where a product doesn’t meet all the customers demands and needs you
must ensure that:
 You don’t have a product in your range that meets the customer’s demands
and needs better than the on you are recommending; and
 You point out to the customer which demands and needs haven’t been met
by your recommendation so that the customer can make an informed
decision whether to continue to take out the policy.
2.2
The following sections detail what the FSA mean by ‘demands and needs’, and
what factors you need to take into account when assessing and making a
recommendation to the customer.
Initial Disclosure Document (IDD)
2.3
The firm’s requirement is that the IDD should be issued at the start of the sales
process and if necessary, on its amendment or renewal. If initial contact is made by
telephone the CIDD or IDD must be sent in the post within 5 working days or
immediately after the conclusion of the contract, whichever is sooner.
2.4
With some types of insurance, the customer might ask for a quick quote to get a
rough idea of costs, without providing full details needed to produce a definitive
figure. You can provide ‘quick quotes’ without triggering an IDD as long as the
quote can’t be accepted, and lead to a sale.
Fees and Commission Disclosure
2.5
The firm’s IDD details the amount of any fees, other than premium monies, payable
by the customer. This must be given before the customer incurs liability to pay the
fee, or before conclusion of the contract, whichever is earlier.
2.6
For insurance business you are not required to inform the customer of how much
commission you will receive but if you wish to disclose this to the customer then you
may do so. However, please note, agency law requires you to disclose commission
on request if you are the customer’s agent.
2.7
The FSA rules do require you to disclose commission to commercial customers if
requested for non-investment insurance business. If asked, you must disclose any
commission earned by you or an associate in a durable medium in cash terms.
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Fact find
2.8
Before making a personal recommendation, you must seek relevant information
about the customer’s circumstances and objectives to identify what their
requirements are.
2.9
Where possible you must take account of facts affecting the type of insurance
recommended, such as relevant existing insurance policies the customer already
holds. You should use any relevant details about customers at your disposal – e.g.
details gathered in respect of other policies you’ve previously advised them on.
2.10
You must explain clearly to customers their duty to disclose all circumstances
material to a policy, what needs to be disclosed and the consequences of nondisclosure. That is, their claim could be rejected or reduced if they give false
information or fail to disclose important information. Ensuring the customer
discloses all information should be carried out by asking clear questions relevant to
the policy.
Existing Plans
2.11
You should base your recommendation on what the customer tells you. If they tell
you they haven’t got any relevant existing plans, you can take their word for it.
However you should document it clearly on file.
2.12
If you have details of the customer’s existing cover at your disposal, you must take it
into account when making a recommendation. If however a customer mentions that
they think they already have an insurance policy, but is hazy about the details and
you’re aware that it is likely to affect the suitability of any recommendation you
make, you must either:
 Not recommend anything until you have full details of the existing policy; or
 Explain that your recommendation may not be suitable because you haven’t
taken full details of existing cover into account.
2.13
If you decide on the second option, you must insert an appropriate caveat in the
Statement of Demands and Needs confirming that your recommendation may not
be suitable and the reason for this.
Affordability
2.14
To assess affordability, you need to find out how much disposable income is
available. You have a responsibility to assess whether the customer can afford
your recommendation and must take into account:
 The information your customer provides about their income and
expenditure, and any other resources they have available (unless you have
reason to doubt it, in which case you should investigate further); and
 Any anticipated changes to those circumstances.
Suitability of Recommendation
2.15
In line with Principle 6, you should take reasonable steps to ensure that a customer
only buys a policy under which they are eligible to claim benefits.
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2.16
If, at any time, you find that parts of the cover do not apply, you should inform the
customer immediately so they can take an informed decision on whether or not to
proceed with the policy.
2.17
There are three other factors you should always consider when deciding whether a
particular insurance product meets the customer’s demands and needs.
 Is the level of cover enough for the customer;
 Cost – versus other policies in your range that cover similar demands and
needs;
 Relevance of any exclusion, excesses, limitations or conditions in the policy.
2.18
It is recognised that buying insurance is about balancing the customer’s desire, or
need, for protection against certain risks against the amount they can afford, or is
willing to pay in premiums. Cost and risks covered will obviously pull in different
directions but they are both relevant to a customer’s demands and needs.
2.19
A customer may decide to lower their sights in terms of the risks insured, or levels
of cover, in order to save money. Where this occurs you should ensure the
customer is aware of the consequences, this should then be reiterated within the
Statement of Demands and Needs so that the customer is clear on the policy taken
out. For example: ‘you were interested in accidental damage cover, but the extra
premium was more than you wanted to pay, or could afford, so you decided to do
without it’.
Research
2.20
For products where you have a range of Insurers to choose from, you must
recommend the product that best meets your customer’s demands and needs. You
must keep details and evidence of why a particular product and Insurer has been
recommended on the client file for a period of at least six years from the date on
which you made the recommendation.
Product Disclosure
2.21
You are responsible for providing the following information to the customer, in a
durable medium and in good time before conclusion of the contract.
 Initial Disclosure Document;
 Policy Summary;
 Statement of Price;
 Statement of Demands and Needs
2.22
You must also draw their attention to the importance of reading the Policy Summary
and other documents, in particular to any significant and unusual exclusions or
limitations that may apply.
Policy Summary
2.23
The Policy Summary must be sent in good time before the conclusion of the
contract in writing or other durable medium.
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2.24
Unlike the mortgage KFI, there is no set format for the Policy Summary in the FSA’s
rules. The key points to note are as follows:
 If not a standalone document, it must be prominent, clearly marked as key
information to be read, and separate from other content of the document it is
included with;
 Insurers can use the key features document format instead of a Policy
Summary (likely to be standard practice for pure protection – the KFD
format is already widely used in this market);
2.25
The Policy Summary should include the following information;
 The FSA’s Key Facts Logo must be at the top of the Policy Summary.
 Statement that the full terms and conditions are in the Policy Document;
 Name of the Insurer;
 Type of insurance and cover,
 Significant features and benefits;
 Significant and unusual exclusions or limitations and cross-references to the
relevant policy document provisions;
 Duration of the policy;
 Statement that customers need to review and update cover periodically to
ensure it remains adequate;
 Existence (or not) of a cancellation period, and its duration;
 Contact details for notifying a claim;
 How to complain and that complaints may subsequently be referred to the
Financial Ombudsman Service;
 Statement about the Financial Services Compensation Scheme.
2.26
A significant exclusion/limitation is one which tends to affect a customers buying
decision. An unusual exclusion/limitation is one not normally found in comparable
policies.
Statement of Price
2.27
Where a policy is bought in connection with other goods or services you must,
before conclusion of the contract, disclose the premium separately from any other
prices and confirm whether buying the policy is compulsory.
2.28
Price information should be given in writing or another durable medium in good time
before conclusion of the contract.
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2.29
The statement of price must include the following details:
 The total premium – or at least the basis for calculating it, that a customer
can use to verify it later on;
 For policies lasting more than one year: how long the initial premium is
valid, and whether and when it will be reviewed;
 Any fees, administration charges, and taxes paid by the customer via the
adviser in addition to the premium including any interest charged on the
premium (e.g. if an annual or single premium is added to the loan) and a
statement identifying the possibility of any taxes not payable via the adviser;
 Where insurance has been purchased in connection with other
goods/services the premium must be separate and reference made to
whether the insurance is mandatory when purchasing other goods or
services or not;
 A statement identifying separately the possibility of any taxes not payable
through the firm;
 The total price of the insurance.
Statement of Demands & Needs
2.30
The Insurance Mediation Directive (IMD) requires a Statement of Demands and
Needs’ (D&N) to be provided to customers for all insurance sales, in writing, prior to
the conclusion of the contact. This requirement is reflected in the FSA’s insurance
rules under ICOBS.
2.31
Elements that should be covered in the D&N are:
 Confirmation that the IDD and other important document have been
provided to the customer;
 The customers demands and needs;
 That you have personally recommended the contract;
 The reason for personally recommending the contract including contract
features not available anywhere else, price, or service levels;
 Why the customers demands and needs
recommended contract suitable for the customer;
combined
makes
the
 The complexity of the insurance proposed;
 Cancellation rights;
 The importance of reading the documentation issued before the end of the
cancellation period to check that the policy is suitable.
2.32
The D&N must be in plain English; concise and clear. Any technical terms/jargon
must be explained.
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2.33
The Statement of Demands and Needs is arguably the most important document
issued to the customer as this will confirm not only why recommendations have
been made, but also why it is considered suitable to the customers’ circumstances
(present and future). A D&N letter will be judged, not simply as it appears today but
also how it will appear to the customer in a few years time.
2.34
It is highly probable that a customer, if asked, could very well explain why a contract
was set up, in the days or weeks after receiving the policy document. It is much
less likely that the same customer could do this, some, two years or more after the
event. A high quality letter should contain enough information and be phrased in
such a way to allow that same customer to read through it again and, irrespective of
the time elapsed, immediately understand what it is they have and why they have it.
2.35
In most cases, you should issue the D&N before the contract is concluded. The
exceptions to this are:
 Where the customer requests one to be sent;
 Customer requests immediate cover;
 Buys over the telephone and the information is provided orally.
2.36
If any of the above occurs, the FSA rules sate that the D&N must be provided
immediately after the contract concludes.
2.37
[Firm Name’s] policy is that you provide the D&N within 3 business days of the
customer accepting your recommendation or prior to conclusion of the contract
whichever is the earlier; this should then make it easy to comply with the FSA’s
rules, regardless of the individual circumstances of the sale.
Cancellation Period
2.38
The following information must be provided to the customer in writing or another
durable medium in good time before conclusion of the contract, or earlier if
available:
 The existence or absence of a right to cancel;
 The duration of any cancellation period;
 Any conditions for exercising it;
 Information on the amount the customer may be required to pay if they
exercise it;
 The consequences of not exercising the right to cancel;
 Practical Instructions on how to exercise cancellation rights – including the
address to notify.
2.39
The customer has a right to cancel, without penalty within:
 30 days for a policy which has elements of a pure protection contract or
payment protection contract;
 14 days for any other insurance policy or distance contract.
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2.40
The cancellation period starts from either:
 The day the contract concluded, except in respect of a pure protection
policy where the period begins when the customer has been informed the
contract has concluded; or
 The day on which the customer receives the contractual terms and
conditions and any other pre-contractual information, if that is later than the
date referred to above.
2.41
Cancellation rights apply to new sales and renewals, with a few specific exceptions:
 A travel and baggage policy or similar short term policy of less than one
months duration;
 A claim has already been made within the cancellation period that leads to
the contract being terminated before the customer decides to cancel;
 A pure protection contract lasting six months or less which is not a distance
contract;
 A pure protection contract taken out by the trustees of an occupation
pension scheme or by an employer or partnership to secure benefits for its
employees or the partners in the partnership.
2.42
A ‘similar short-term policy’ is any policy where the event or activity being insured is
less than one month’s duration. ‘Duration’ refers to the period of cover rather than
the period of the contract.
2.43
Where no cancellation rights exist, the customer must be informed of this fact.
Claims Process
2.44
The aims of the FSA’s claims handling rules can be summarised as follows:
 Claims are handled fairly and settled promptly;
 Customers receive information on the claims handling process – and
appropriate information on its progress;
 Advisers disclose and manage any conflicts of interest that may exist.
2.45
This means that Insurers must:
 Have systems and controls in place which take account of foreseeable
peaks in demand, to allow them to deal with claims promptly;
 Ensure claims handling staff are competent to carry out that function;
 Give customers reasonable guidance to help them make a claim.
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2.46
You must provide the following information about the claims handling process, this
is normally contained in the Policy Summary;
 The address, telephone number or other point of initial contact for notifying
a claim; and
 The information the customer must provide to the insurance undertaking
when notifying a claim.
2.47
Where you are notified about a claim you must forward it to the Insurer promptly, or
else tell the customer you can’t deal with the notification and provide them with
details of who can.
2.48
If you help by getting involved with claims, then:
 You must act with due care, skill and diligence when acting for the customer
in relation to a claim;
 You must not put yourself in a situation where your own position or duty to
any person you act for, conflicts with your duty to the customer;
 You act for the customer (not the Insurer) when you arrange policies or deal
with claims – so no conflict should arise.
Re-broking Insurance
2.49
You should only re-broke insurance policies if it is in the customers interests to do
so. If you do advise customers to replace an existing policy with another one, you
must:
 Complete a discontinued plan form to compare cover provided by the old
and new policy and send a copy to the customer with the D&N letter;
 Point out any significant differences in cover to the customer;
 Remember that some long-term ‘insurance’ policies are designated
investment contracts, so you can’t advise customers to cancel them to
replace with a plan that you can advise on.
 Be particularly careful about recommending that customers re-broke critical
illness cover as it is usually less generous than it used to be.
2.50
One of the main benefits of critical illness cover (CIC) is that it pays out on
diagnosis of cancer or a heart attack. However, advance in medical technology
means that mild forms of cancer/heart attacks are easier to diagnose than they
used to be, leading to a surge in claims. Insurers have had to respond to this trend
by tightening up the medical definitions they use in their CIC contracts, to keep the
risks they face down, and the premiums affordable for customers. So new CIC
policies typically have less generous cover than older ones.
2.51
Another consideration to take into account is whether the old contract has
guaranteed premiums. It’s much harder to find guaranteed premiums for the whole
term of the CIC contract than it used to be. Most new products have reviewable
premiums. One question you should ask yourself before recommending a switch is
whether supposedly long-term protection products are ‘fit for purpose’ when the
premiums could go through the roof after a few years? Could this lead to the
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customer cancelling the policy at a time when the risks he or she needs protection
against are most likely to crystallise?
2.52
Exception – You do not need to complete a discontinued plan form for re-broking
buildings and contents policies when they come up for annual renewal. But you
still need to make sure the recommendation is suitable, and point out any
disadvantages of the switch. You may decide to use the discontinued form to help
you do this anyway, even though it’s not mandatory in this situation.
Group Insurance Policies with Multiple Policyholders
2.53
Advisers that sell group protection policies to, for example, a local employer for the
benefit of its employees, must inform them to:
 Provide a copy of the Policy Summary to each individual policyholder, and
tell them a copy of the Policy Document is available on request;
 For replacement group policies – inform each policyholder of any changes
to the information in the Policy Summary.
Product Disclosure on ‘Distance Contracts’
2.54
Some insurance sales are ‘distance contracts’ as defined by the Distance Marketing
Directive. The rules for the timing, and form, of product disclosure information for
distance contracts are different and much more complicated than the standard
rules.
2.55
A ‘distance contract’ is sold through a systematic distance selling operation. This
means advisers provide special facilities for the customer to complete the whole
sales process without any face-to-face contact. If most of the business is face-toface, and only the occasional sale involves no such contact, advisers will not be
caught by the special rules applying to distance contracts.
2.56
When carrying out insurance sales by distance the information provided either by
phone or in a durable medium must be clear, fair and not misleading.
2.57
The following contractual terms and conditions and information must be provided in
writing or another durable medium in good time before conclusion of the contact:
Distance Marketing Information
The Firm
1
The name, address and main business of the firm.
2
Where the firm has a representative, the name and address of that
representative.
3
Statutory Status Disclosure Statement.
The Financial Service
4
Description of the main characteristics of the contract, including
significant benefits, exclusions and limitations, duration and price
information.
5
Total price to be paid, including fees, charges and expenses, and all
taxes paid through the firm, or when an exact price cannot be indicated,
the basis for the calculation of the price.
6
Where relevant, notice indicating that the financial service is related to
instruments involving special risks related to their specific features or the
operations to be executed or whose price depends on fluctuations in the
financial markets outside the firms control and that past performance is
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no indicator of future performance.
7
Notice of the possibility that other taxes or costs may exist that are not
paid through the firm or imposed by it.
8
Any limitations on the period for which the information provided is valid,
including a clear explanation as to how long a firms offer applies as it
stands.
9
The arrangements for payment and performance.
10
Details of any specific additional cost for the customer for using a means
of distance communication.
The Distance Contract
11
The existence or absence of a right to cancel, and where there is such a
right, its duration, the conditions for exercising it and amount which the
customer may be required to pay.
12
Minimum duration of the contract, in the case of services to be performed
permanently or recurrently.
13
Rights to terminate the contract early or unilaterally, including any
penalties imposed.
14
Practical instructions for exercising any right to cancel, including the
address to which any cancellation notice should be sent.
15
The EEA state or States whose laws are taken by the firm as a basis for
the establishment of relations with the customer prior to the conclusion of
the contract.
16
Any contractual clause on law applicable to the contract or on the
competent court, or both.
17
In which language the firm with the agreement of the customer will
communicate during the duration of the contract.
Redress
18
How to complain to the firm.
19
Whether compensation may be available from the compensation scheme.
2.58
Many of the above items will be contained within the firms IDD, policy summary,
statement of demands and needs etc however the adviser should take care that all
the above is clear within the documentation sent to the customer.
Distance Contracts - Telephone
2.59
Where the insurance sale is carried out by telephone the adviser must first make
their identity and purpose of the call explicitly clear at the beginning of the
conversation.
2.60
The adviser may provide the abbreviated distance marketing information over the
phone where the customer has given their explicit consent. This should then be
followed up with the full distance marketing information highlighted in the table
above in writing before conclusion of the contract.
1
2
3
4
Abbreviated Distance Marketing Information
The identity of the person in contact with the customer and link with the
firm.
Description of the main characteristics of the contract, including
significant benefits, exclusions and limitations, duration and price
information.
Total price to be paid, including fees, charges and expenses, and all
taxes paid through the firm, or where an exact price cannot be indicated,
the basis for the calculation of the price.
Notice of the possibility that other taxes or costs may exist that are not
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paid through the firm or imposed by it.
The existence or absence of a right to cancel, and where there is such a
right, its duration, the conditions for exercising it and amount which the
customer may be required to pay.
That other information is available on request and what the nature of that
information is.
5
6
2.61
Where a discussion takes place during the sale of a protection or PPI product that
covers any of the main characteristics (significant benefits, exclusions and
limitation, price and duration) you must talk about all of them. The following
information should be provided orally as well as in writing in addition to the
marketing directive information:
 The total policy cost;
 The fact that interest is payable on the premium; and
 Regular payments of the insurance
2.62
If the contract has been concluded at the customers request using a means of
distance communication that does not enable the provision of the distance
marketing information in good time before conclusion of the contract then the
information must be sent in writing immediately after the conclusion of the contract.
3.
RENEWALS AND MID-TERM CHANGES
3.1
If a product with a greater than one-year duration is renewed or the policy has
altered, it must be treated as a new sale.
3.2
Products that automatically renew monthly and are cancellable at the customer’s
discretion are exempt from renewal rules. So they carry on without the need for any
further information to be issued, until the customer decides to cancel them, or until
the Insurer changes the premium or cover details.
3.3
You only need to read this section if involved in forwarding renewal information to
customers as opposed to the information being sent directly by the Insurer.
3.4
If a product with an annual cycle is due for renewal, the customer should be given:
 Renewal terms, in a durable medium, at least 21 days before expiry; or
 At least 21 days notice that the Insurer is not willing to renew; or
 At least 21 days notice that you no longer deal with that Insurer.
3.5
Unless:
 You know the customer doesn’t wish to renew. E.g ASU is due for renewal,
but the loan has already been repaid; or you rang the customer to check
about renewal and they said ‘they didn’t want it’; or you wrote to them about
renewal and received no reply;
 You have already told the customer you don’t wish to act for them on
renewal, or that the Insurer wont renew;
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 The customer has requested an extension to the existing contract.
3.6
The following information must be contained in the renewal terms:
 Any changes to the terms of the policy, and an explanation of those
changes, where necessary;
 Any changes to the directive-required information;
 A new statement of price;
 A prominent statement telling the customer that they can request a new
policy document.
3.7
The Insurer must supply you with the renewal terms in good time to allow you to
meet your obligations to the customer.
3.8
Where you have made a personal recommendation to renew you will need to issue
a personalised Statement of Demands & Needs with the renewal documents. The
letter should ask the customer to confirm whether any of their needs/circumstances
have changed since the original sale.
Mid Term Changes
3.9
In addition to the policy conditions, both general and special, you must notify the
customer of any change to:
 The name of the insurer, its legal form or address;
3.10
In addition, all the following information must be communicated in writing or other
durable medium before conclusion, in the event of a change in the policy conditions:
 Definition of each benefit and each option;
 Term of the contract;
 Means of terminating the contract;
 Means of payment of premiums and duration of payments;
 Information on the premiums for each benefit, both main benefits and
supplementary benefits, where appropriate.
 A prominent statement telling the customer that they can request a new
policy document.
3.11
When explaining the implications of a change, you should explain any changes to
the benefits and significant or unusual exclusions arising form the change.
4.
RECORD KEEPING REQUIREMENTS
4.1
The FSA’s rules require firms to take reasonable care to make and retain adequate
records. It is also noted that firms should bear in mind the need to deal with
requests for information from the FSA as well as queries and/or complaints from
customers which may require evidence of matters such as:
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 The reasons for a personal recommendation;
 What documentation was provided to a customer;
 How claims have been settled and why.
4.2
[Firm Name] policy is that client files are held for a minimum of 6 years and the
following kept on file:
 Copy of the IDD issued to the customer;
 Insurance Factfind;
 Copy of the Statement of Demands & Needs;
 Discontinued plan form (if relevant);
 Research;
 Policy Summary/Illustration;
 Statement of Price.
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