RAC FINANCIAL SERVICES LIMITED

Limits on what they may do

• 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 (1)(b)(iii) above RAC must: (a) provide appropriate remediation to those customers who have suffered detriment as a result of the compliance failures; (b) provide each customer an appropriate opportunity to be remediated and provided with assistance 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) RAC must ensure that at all times it complies with the relevant FCA rules and guidance when dealing with affected customers, including FCA Principles. 20 March 2018

• Compliance general insurance rules ICOBS 6.1.12A

  Requirement 3 (1) RAC must ensure that it is fully compliant with its regulatory responsibilities in the following areas by the corresponding dates: Area Date (a) Renewal process (requirements are specified in ICOBS 6 including compliance with ICOBS 6.1.12A) By 30 April 2018 (b) Email renewal invitations 26 April 2018 (c) Postal renewal invitations 30 April 2018 (d) Affinity and Partner Cohort email invitations 2 August 2018 (e) Affinity and Partner Cohort postal invitations 8 August 2018 (2) RAC 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. (3) If, for timing changes arising as a result of circumstances outside of RAC's control, RAC is unable to complete the actions in (1) by the dates specified it must communicate these to the FCA as soon as possible. 20 March 2018

• Compliance general insurance rules ICOBS 6.1.12A

  Requirement 1 (1) RAC must, by 31 March 2018: (a) Identify all of the occasions, on or after 1 April 2017, where RAC sent a customer a renewal invite (which has the meaning in ICOBS 6.1.12A(1) and (2) and applies only to those policies paid annually on the understanding that RAC provides no premium finance) that did not display all of the following as key information: (i) the premium payable; (ii) the previous year's premium paid; and (iii) the 'shopping around' disclosure. (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 (b)(i) where the customer renewed their policy with RAC, 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 (b)(ii), including deadlines for achieving those actions, and proposals in relation to customers that could not be contacted. (2) RAC must use best endeavours to complete the following actions by the dates specified below: (a) commence initial communications with affected customers by 30 June 2018; (b) complete initial communications with affected customers by 30 November 2018; and (c) complete the actions included in the detailed plan by 31 December 2018. (3) If, for timing changes arising as a result of circumstances outside of RAC's control, RAC is unable to complete the actions in (2) by the agreed timescales it will communicate these to the FCA as soon as possible. (4) Communications with potentially affected cohorts of customers must be made in a way that satisfies Requirement 2 and; (a) explain that RAC has failed to comply with their regulatory responsibilities in ICOBS 6; (b) explain RAC's intention 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 6.1.12A. 20 March 2018