The growing compliance oversight placed on the insurance industry is making it very difficult for insurance companies to comply. Insurers are required to identify, assess, communicate, manage and report on operational risks posed by intermediaries, brokers and binder holders. This onerous compliance process can be very challenging requiring ongoing assessments to:

• Communicate and track declarations of compliance and regulatory changes for all intermediaries, brokers and binder holders.
• Ensure the validity, accuracy, completeness and security of any information provided by intermediaries, brokers and binder holders as well as being able to report appropriately on this;
• Ensure the adequacy of governance, risk management, internal control frameworks and the ability to comply with applicable laws.
• Ensure the fitness and propriety of the binder holder, including any specific technical expertise required to perform the binder functions;
• Ensure that the binder holder has the operational ability to achieve integration between the insurer’s and binder holder’s IT systems so that the insurer has access to up-to-date, accurate and complete data held by the binder holder as and when requested by the insurer and when required by the binder agreement, or by regulatory requirements relating to data management including the Policyholder Protection Rules.
• The GOI 5 Standard sets out the concept of materiality and the conditions that determine when an outsourcing arrangement requires prior regulatory notification. It sets out matters that an insurer must consider prior to an outsourcing decision and legal provisions that must be included in any outsourcing contract.
• Review, manage and report on poor customer outcomes.