Insure4Less Teoranta T/A Kerry Insurance Group

the Central Bank has approved in writing the appointment of the person to perform the function. The Central Bank’s investigation found that the three new directors were appointed by the Firm in January 2018, following the resignation of the then PCF holders at the Firm. At the time of the appointments, the Firm had not submitted any applications to the Central Bank to seek preapproval for the new role holders. Consequently, each of the three appointments, being made without the prior written approval of the Central Bank, amounted to a separate prescribed contravention of Section 23 of the 2010 Act. REMEDIATION The Central Bank is satisfied that the Firm has now remediated the failings identified during this investigation. The Central Bank has since approved three individuals for PCF roles in the Firm. PENALTY DECISION FACTORS In deciding the appropriate penalty to impose, the Central Bank considered the ASP Sanctions Guidance issued in November 2019. The following particular factors are highlighted in this case: Nature, seriousness and impact of the contraventions  The actions of the Firm were reckless as they were aware or ought to have been aware that appointing individuals to PCF roles without approval would result in a breach of their regulatory requirements.  The impact of the contraventions - the failure of the Firm to apply for PCF approval for the three individuals resulted in the Firm trading with no approved PCF holders for a significant length of time.