Context
The FCA has published a web page regarding the numbers of skilled persons reviews it requested following concerns about aspects of certain regulated firms’ activities.
Where it wants an in-depth analysis of a firm, the FCA can get a view from a third party (known as a ‘skilled person’). If the FCA contracts directly and appoints the skilled person firm, the FCA will communicate with the regulated firm during the appointment process and the review itself. The FCA will conduct a tender process, where appropriate, to identify the most suitable skilled person firm.
Key points to note
- Links above show information about the skilled person reviews the FCA have commissioned over each financial year in the FCA Annual Reports.
- The published data shows a total of eight skilled persons reports being commissioned in the general insurance and protection sector during the first half of 2023/24 (so April to September 2023), with one in Q1 2023/24 and seven in Q2 2023/24.
- From the data in the tables it is possible to deduce (certainly for Q2) that most of these were for ‘portfolio’ (‘flexible’) supervision firms as only three out of 18 were for dedicated (‘fixed’) supervision firms. The message here could be that you are not too small to have a s166 skilled persons review (albeit that there are probably only about 20 ‘fixed’ supervision general insurance firms (insurers and intermediaries), so there will be a number of large ‘flexible’ supervision firms).
- In terms of the subject matter (and assuming that the financial crime reviews are in the retail banking and payments sectors) then they are likely to be about “Controls and Risk Management Frameworks”.
Next actions
None – for information and awareness.