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It also asks firms to think carefully about whether they are introducing, arranging or even advising customers on purchasing a contract of insurance – and whether they need to reflect that with a change in permissions. The letter contains proposed guidance on the issues it has highlighted. The letter follows a review carried out by the FSA between June and September 2010. Firms now have until 8 August 2011 to respond to the proposed guidance. As well as asking aggregators to consider whether or not they need to extend their permissions it also sets out examples of good and bad practice. Areas of concern highlighted by the FSA include: • making it clear that firms should take responsibility for checking eligibility or disclosure, rather than putting the onus on the customer; • reminding firms to check whether they hold the correct permissions, in particular where they may be inadvertently giving regulated financial advice without holding that permission; • reminding firms who are using a ‘white label’ service* to make it clear to customers which firm they are actually dealing with and who they should complain to should they wish to do so; and • reminding firms that use a ‘white label’ service to check that their provider holds the necessary permissions to conduct regulated activity. In its review the FSA identified two business models: price comparison websites using a proprietary tool, and ‘white label’ websites (or hosts) that use the comparison tool of a third party (provider).
Richard Anthony Oakes, Sharon Linda Oakes & Ashley Burton trading as Oakes Insurance Consultants are
authorised and regulated by the Financial Services Authority. Number 307170
Registered office: Oakes House, Derby Road, Long Eaton, Nottingham NG10 1PD