MICHAEL PETTIFER INSURANCE BROKERS LIMITED

Limits on the record

• Restriction on placing business with, or providing services to, overseas insurance undertakings

  Business Restriction 1. The Firm must not carry on any regulated activities in relation to placing, whether directly or through its Appointed Representatives, any insurance policy with (or for) an overseas insurance undertaking which does not have FSMA permissions to carry on insurance business in the UK. For the avoidance of doubt this includes arranging new policies and renewing any existing policies. 2. The Firm and its Appointed Representatives must cease providing services to any overseas insurance undertaking which does not have FSMA permissions to carry on insurance business in the UK, that are ancillary to/carried on in connection with any regulated activity, in relation to new or existing business. 3. The Firm may seek written consent from the FCA to recommence activities under paragraphs 1 or 2 for example where it can objectively demonstrate the arrangements do not require the overseas insurance undertaking to be authorised in the UK or where it is necessary to maintain existing services (which the insurer is unable to provide itself or through another person) to avoid material detriment to UK customers. Notification to insurers 4. The Firm must, within 5 working days of these Requirements taking effect, notify any overseas insurance undertakings with whom it, or its Appointed Representatives, placed the relevant business or have arrangements under which they could place relevant business of the effect of the restrictions in paragraphs 1 and 2. 5. The Firm must provide to the FCA copies of the notifications made as per the requirement in paragraph 4 for each of the overseas insurance undertakings, within 24 hours of sending them. Past Business Review 6. The Firm must, within 3 weeks of these Requirements taking effect, carry out a past business review in relation to the relevant business (the “Past Business Review”) and provide the FCA with a report on its findings. 7. The Past Business Review in paragraph 6 must: a. identify any customer with or for whom the Firm and its Appointed Representatives placed a policy with an overseas insurer; b. identify whether there is a risk of customer harm. Amongst other considerations, this should include whether any policies have been placed in breach of ICOBS, PROD & Consumer Duty rules (e.g. where the Firm or its Appointed Representatives did not ensure the policies met customers’ demands and needs); 8. Where the Firm identifies any risk of harm to existing customers it must provide the FCA with a copy of its remediation plan for those customers within 4 weeks of these Requirements taking effect. Notification to Customers 9. The Firm must, within 5 working days of these Requirements taking effect, notify in writing all customers impacted by the restrictions in paragraphs 1 and 2, save for those subject to the exception in paragraph 3, of the imposition and effect of these Requirements in a form to be agreed in advance with the FCA. Record retention 10. The Firm and its Appointed Representatives must secure all books and records and preserve all information and systems relating to the Firm’s regulated activities, and must retain these in a form to be notified to the FCA in writing, such that they can be provided to the FCA, or to a person named by the FCA, promptly on its request. Effective Date 11. The Requirements in this application are to take effect immediately Publication  12. The Requirements will be published on the Firm’s entry on the Financial Services Register.   Definitions 13. In this application: Overseas insurance undertaking - An insurance undertaking which has its registered office (or, if it has no registered office, its head office) outside the United Kingdom and is not an authorised person Relevant business - Insurance policies arranged by the firm, whether directly or through its Appointed Representatives, that were effected by an overseas insurance undertaking