Hastings Insurance Services Limited

Limits on what they may do

• 1 Compliance general insurance rules ICOBS 6.1.12A

  Requirement 1 (1) Hastings must, by 11 May 2018: (a) Identify all of the occasions, on or after 21 February 2017, where Hastings may have sent a customer a renewal invite (which has the meaning in ICOBS 6.1.12A(1) and (2)) that did not include the correct previous year's premium paid in the form specified in ICOBS 6.1.12A(3). (b) Provide the FCA in writing with: (i) a record of the number of occasions (counting separately each occasion for the same customer) identified pursuant to (a) above; (ii) confirmation that it has identified all of those occasions in (a) where the customer renewed their policy with Hastings, and the number of those occasions; and (iii) a detailed plan of the actions it will take to identify and contact potentially affected cohorts of customers within (a), including deadlines for achieving those actions, and proposals in relation to customers that could not be contacted. (2) Hastings must use best endeavours to complete the following actions by the dates specified below: (a) commence initial communications with affected customers by 1 May 2018; (b) complete initial communications with affected customers by 31 August 2018; and (c) complete the actions included in the detailed plan by 31 October 2018. (3) Communications with potentially affected cohorts of customers must be made in a way that satisfies Requirement 2 and: (a) explains how Hastings has failed to comply with its regulatory responsibilities in ICOBS 6; (b) explains how Hastings intends to provide appropriate remediation to those customers who have suffered detriment as a result of those failures in accordance with the principles outlined in Requirement 2; and (c) include the information the customer should have been given on each occasion, in a way that complies with the requirements in ICOBS 6 and ICOBS 6.1.12A. The requirement has effect from 27 April 2018

• 3 Compliance general insurance rules ICOBS 6.1.12A

  Requirement 3 (1) Hastings must ensure that it is fully compliant with its regulatory responsibilities in the following areas by the corresponding dates: Area Date (a) Renewal process 30 April 2018 (b) Email renewal invitations 30 April 2018 (c) Postal renewal invitations 30 April 2018 (2) Hastings must send confirmation to the FCA that it complies fully with its regulatory responsibilities in Requirement 3 (1)(a) to (c), and provide details of the steps it took to satisfy itself of this by 30 April 2018. The requirement has effect from 27 April 2018

• 2 Compliance general insurance rules ICOBS 6.1.12A

  Requirement 2 (1) For all cohorts of potentially affected customers identified in the detailed plan pursuant to Requirement 1 above Hastings must: (a) provide appropriate remediation to those customers who have suffered detriment as a result of the compliance failures; (b) include the options and assistance available to customers to be able to achieve remediation where appropriate; and (c) ensure that each customer has been given appropriate opportunity and sufficient support or assistance to be remediated where appropriate. (2) Remediation requires the firm to work under the principle that each customer must be placed back in the position they would have been in had they been provided with renewal invitation documents that complied with the regulatory requirements. (3) Hastings must ensure that at all times it complies with the relevant FCA rules and guidance when dealing with affected customers, including FCA Principles. The requirement has effect from 27 April 2018