Keystone Insurance Limited

Background Keystone is a retail intermediary that operates in the commercial insurance market and is regulated under the European Union (Insurance Distribution) Regulations 2018. The Central Bank’s investigation stemmed from an onsite inspection of the Firm in June 2017. A risk mitigation programme was issued to Keystone in November 2017, requiring Keystone to refund all customers who had been identified as overcharged, and amendments to Keystone’s communications to customers on fees to make them clearer and code compliant. Keystone complied with the requirements of the risk mitigation programme within the deadlines specified. The Breaches Further details on the breaches are set out below. (i) Overcharging The investigation found that Keystone overcharged customers fees for placing insurance, processing mid-term adjustments and processing cancellations of insurance policies, in excess of the maximum fees allowed to be charged under Keystone’s Terms of Business. This overcharging was uncovered as a result of an inspection carried out by the Central Bank in June 2017. The investigation found 62 customers were overcharged in total the sum of €9,964.36. Keystone has admitted breaching General Principles 2.1 and 2.2 of the Code in that it failed to treat customers fairly and professionally, and with due skill care and diligence, when charging those customers fees for Keystone’s services. (ii) Provision of unclear communications to customers The investigation found that Keystone only set out key information on applicable fees in small print, at the foot of invoices and in words rather than numbers.