The key to successfully managing your compliance obligations is to ensure that all your people are on the same page – this requires a consistent, documented approach to compliance & training.
Your people includes employees, authorised representatives, distributors and service providers acting on your behalf.
General Insurance Obligations
AFS Licensees must ensure that its representatives:
- comply with the financial services laws; &
- adequately trained (including by complying with the CPD provisions), and are competent, to provide those financial services
Subscribers to the GI Code of Practice must:
- ensure Employees and Distributors to receive appropriate education and training;
- that claim Service Suppliers and their employees are qualified by education, training or experience
Insurance brokers under the Brokers Code of Practice must:
- ensure all of their employees, agents and representatives receive appropriate education and training to provide their services competently; and receive training on the Code at least once every year.
It is obvious from the above that the training and competency obligations are specific and must be documented to demonstrate evidence of compliance.
Compliance training
To often I observe that organisations simply mandate that their employees and others acting on their behalf must undertake xx number of hours each year or achieve 20/25 CPD or CIP points.
This requirement, of itself, does not comply with your Code or financial service laws obligations.
The training must be relevant & cover financial service laws, Industry Codes and your general insurance products and services.
Key principles
- The training must be conducted during induction and at least annually. That is there is a regular, systematic approach to training
- The training must cover the financial service laws, the relevant Industry Code and the products and services being provided by your business
- Training must be recorded in a register (for Licensees, this is a regulatory requirement
- Responsible Managers should undertake specific training designed for responsible managers
- Compliance measures should be documented in a tailored, fit-for-purpose & easy-to-read manual and compliment the training. (Contact me for assistance)
- Your people need constant reminding about raising incidents & complaints through FAQs, standing meeting agenda items, attestations etc. This ensures training is put into practice
- Use breach investigations and quality assurance activities as an oportunity to provide refresher training when gaps are identified
- The training should use business case studies and scenarios and test understanding