TOWARDS the end of 2021, a number of new information/ guidance documents and templates were added to the Compliance section of the Brokers Ireland website. These information/guidance documents related to Assessing Financial Soundness, Cyber Security and Data Protection and we encourage members to assess and use the documents to assist in their firms’ requirements.

In November 2019 at the Central Bank Intermediary Roadshows, the Central Bank advised Brokers of its expectations of Brokers regarding the assessing of the financial soundness of insurers with which the Broker places business. To further assist our members, Brokers Ireland commissioned Milliman to draft Product Provider reports in respect of domestic providers (outlined below) which will assist members carrying out due diligence to meet the Central Bank’s expectations in relation to assessing financial soundness of providers.

  • Life: Zurich Life, Irish Life, New Ireland, Aviva Life and Pensions, Standard Life and Royal London.
  • General: AXA, AIG, Aviva, Allianz, Liberty, RSA, FBD, Travelers, Zurich.

The intention is that these reports will be updated on an annual basis and set out the following:

  • Company profile including its ownership structure, product types, markets, and risk profile;
  • Experience and expertise of the company covering its years in the market, its staff headcount if available and any material changes or events noted in the latest Solvency and Financial Condition Report;
  • The following information as published in the annual Solvency and Financial Condition Report:
  • Premiums written over the last 3 years, gross and net of reinsurance
  • Total technical provisions over the last 3 years, gross and net of reinsurance
  • Eligible own funds, solvency capital requirement and solvency ratios over the last 3 years
  • Own funds split into capital types;
  • Financial rating of the undertaking or its parent at the date of the report;
  • Any published regulatory action taken against the insurer in the last 5 years.

Members should continue to complete the “Assessing soundness” template, which was previously issued to the membership, using the provider reports to assist in carrying out due diligence on providers with which you place business.

Recent cyber-attacks with their damaging consequences highlighted the importance of the need for robust cybersecurity measures to be in place, which are proportionate to the nature, complexity of firms, and the sensitivity of its information and data it holds.

To assist members in this area, Brokers Ireland has together with Saros Consulting* drafted guidance and templates for members in respect of:

Information Technology and Security Risk Management and;

The first part of the guidance introduces how risks should be managed in the firm’s context.

A practical step-bystep guide suggests the minimum steps to implement the processes to ensure that the risks management is running effectively, and any risks identified are successfully addressed.

The second part of the guidance covers the execution of the assessment to evaluate the compliance postion of the firm and identify potential gaps. The accompanying templates will assist members to identify risks, evaluate the compliance of current IT processes and how to build an IT strategy.

IT Incident Management and Business Continuity

The IT incident Management and Business Continuity guidance provides a practical approach to help each member to evaluate their own ability to govern and manage business processes and IT operations and propose a possible way to manage the recovery operations in case disruptive events occurs: the first part covers incident management, and the second part covers the continuity of business.

The accompanying templates and checklists will assist members to manage incidents and operating procedures for backup and restoring business continuity.

Data Protection guidance and templates such as Privacy Statement, Data Protection Policy have also been updated.

We also have a Data Protection Frequently Asked Questions document which acts as a quick reference for queries which members might have. If members have any questions on our guidance documents and templates, members can contact our compliance department on 01-661 3067, email or use our chat facility located on the Brokers Ireland website.

*Saros Consulting was established in 2012 and is headquartered in Dublin city centre. Saros mission is to empower business by providing exceptional IT and Information Security advice. Promoting positive change IT is transformed: from a mandatory business component into a vital engine powering simplicity and security, connectivity, and control, all unified by Saros in-depth understanding.