E-commerce
If a life office does business on line or even advertises on line it is subject to the e-commerce directive rules. The main provisions are as follows,
- certain minimum information must be easily, directly and permanently accessible i.e. name, geographic address, e-mail address and FSA registered number
- there must be clear information about the services provided
- customers must be clearly told how to place an order
- customers must have a means of identifying and correcting input errors prior to making an order
- orders must be acknowledged without delay, although they do not have to be accepted.
The COB rules also apply.
Training and competence rules
These rules were set up by the FSA to make certain that firms spent time ensuring that their employees were properly trained and competent. Competency must be regularly reviewed.
The rules apply to all employees who are in either senior management positions, supervise staff who deal with customers or customers business or who themselves advise and deal with customers.
At the time of employing a member of staff the firm must make certain that they are competent for the job in hand. If not then the person must be adequately supervised and then trained so that they become competent. Once competent the employee must be regularly monitored to see that they remain competent. Any problems observed though the monitoring system then needs to be resolved through additional training or supervision as required.
The Financial Services Skills Commission works with the FSA and has a list of qualifications suitable to test competency. The FSA look at this list when assessing the ability of a new firm to start up in a financial services field.
Training and competency records must be kept for three years.
The training and competency requirements extend to appointed representatives, where it is the authorised firm who has the responsibility.