FBD Insurance plc

Background The Firm provided the Central Bank with a report identifying breaches by the Firm of the 2006 Code. Following review of the report, the Central Bank undertook its own inspection. The report and the Central Bank’s inspection identified concerns regarding the Firm’s failure to ensure it had resources 3 and procedures, systems and controls necessary to ensure compliance with the 2006 Code and formed the basis of this administrative sanctions procedure case. The Firm promptly undertook measures to rectify the issues that were identified. These included the dedication of additional compliance resources, the implementation of new systems and procedures, an enhanced training programme and enhanced controls in respect of outsourced activities in order to prevent recurrence. Penalty decision factors The penalties imposed in this case reflect the seriousness with which the Central Bank treats the relevant contraventions. They also reflect the importance the Central Bank places on consumer protection and the obligation of regulated entities to ensure that they comply with, and have adequate resources and procedures, systems and controls in place to ensure compliance with, the Consumer Protection Code. In particular, the Central Bank considers it unacceptable for firms to outsource regulated activity without appropriate oversight and assurance that the regulated activity is being conducted in accordance with the 2006 Code.