On 9 February, the Central Bank of Ireland (the “Bank”) published its plans for a series of themed reviews and inspections during 2012 with consumer protection remaining a priority for the Bank. The themes include a review of how the revised Consumer Protection Code is being implemented by insurance companies and banks and the suitability of sales of payment protection insurance.
On 13 February the Bank issued a press release setting out the top ten areas that have been identified as likely to areas for enforcement actions this year. The areas earmarked as priority areas for the Bank’s Enforcement Division have been deliberately aligned with the areas for themed inspections
Relevant Themes for Insurance Company Inspections
- How the new Consumer Protection Code is being implemented
- For companies involved in payment protection insurance, the suitability of sales by banks and other lenders
- For life assurance companies, anti-money laundering and counter terrorist financing
Relevant Themes for Insurance Broker Inspections
- How the new Consumer Protection Code is being implemented
- While it will primarily impact banks that are also insurance intermediaries, the suitability of sales of payment protection insurance
Reinsurers are not specifically mentioned in the context of themed reviews. However, given that reinsurance companies have been subject to a thorough industry-wide review in recent times, this is not surprising.
The Central Bank has committed to providing an update to its Programme for Themed Reviews and Inspections for 2012 later in 2012. This update will be part of the Bank’s Annual Performance Statement.
Enforcement Priorities
The following Enforcement Division priorities are relevant to the insurance and reinsurance sectors:
- Retail intermediaries
- Payment protection insurance
- Client asset requirements
- Prudential requirements
- Anti-money laundering and counter terrorist-financing
- Transaction reporting
- Systems and controls
- Timeliness and accuracy of information submitted to the Bank
Contributed by Dianne McMahon and John Larkin.
