The new Fit and Proper Requirements  made provision for six new product categories (subcategories). In this article we discuss three of these product categories.
Three new product categories (namely Long-term Insurance B1-A, Long-term Insurance B2-A and Short-term Insurance Personal Lines A1) were created ‘out of’ three existing product categories (i.e. Long-term Insurance B1, Long-term Insurance B2 and Short-term Insurance Personal Lines). Essentially, certain product types which previously fell into these three ‘existing’ product categories were stripped out and placed into a product category of their own. Because these three new product categories are ‘less complex’, they may for example, require limited underwriting.
FSPs that were already licenced at 1 April 2018 for any of the three existing product categories mentioned above were deemed to have been authorised for the new product category(ies) on the same date as the associated existing subcategory. This means that an FSP licenced, on 1 April 2018, for:
- Long-term Insurance B1 has automatically been granted approval for Long-term Insurance subcategory B1-A.
- Long-term Insurance B2 has automatically been granted approval for Long-term Insurance subcategory B2-A.
- Short-term Insurance Personal Lines has automatically been granted approval for Short-term Insurance Personal Lines A1.
Any FSP which was authorised for one or more of the existing product categories mentioned above, will notice that the FSCA has now added the new product category(ies) to their licence which is reflected on the FSPs profile on the FSCA’s website.
What are the next steps?
FSPs that are affected and whose licences have been updated with the new product category(ies), must update their Representative Registers (both held at the FSP and the central Representative Register maintained by the FSCA), within 3 months of the ‘automatic’ amendment of their licence. This must be done for any representative that the FSP has or wishes to appoint for any of the new product categories.
The FAIS e-portal online system has been updated, which means Key Individuals can log-in to the FSP’s profile on the system and update the central Representative Register. Below is a screenshot of what the central Representative Register on an FSPs profile will look like. For a guide on how to use the FAIS online reporting system, click here.
In addition to updating the Representative Register, FSPs must also ensure that they update relevant documentation to reflect the licence product categories both in respect of the FSP and each Representative that is appointed for one or more of these. This will include updating documents such as the Disclosure documents and Representative letters of appointment.