On 14 May 2020, the UK Financial Conduct Authority (“FCA”) published its final guidance for insurance and premium finance firms, in relation to the fair treatment of customers who are in temporary financial difficulty resulting from the current COVID-19 pandemic. The guidance and associated rules subsequently came into effect on 18 May 2020 and will be reviewed within 3 months of the same in light of any further developments around the current circumstances.
Firms for which this guidance is relevant include the following:
- insurance intermediaries (including appointed representatives);
- premium finance lenders that provide credit to fund the payment of insurance premiums in instalments;
- premium finance brokers that carry on regulated activities relating to credit granted for the purposes of financing insurance premiums in instalments;
- debt collectors; and
- other firms that may be involved in insurance arrangements and/or in relation to the provision of premium finance.
Proskauer’s cross-disciplinary, cross-jurisdictional Coronavirus Response Team is focused on supporting and addressing client concerns. Visit our Coronavirus Resource Center for guidance on risk management measures, practical steps businesses can take and resources to help manage ongoing operations.