FCA refuses authorisation to funeral plan provider
July 29, 2022
What has happened?
In July 2022, the FCA issued a Decision Notice to One Life Funeral Planning Ltd, refusing the firm’s application for authorisation, since One Life could not demonstrate that it was able to meet or comply with the FCA’s regulatory standards.
What are the key points?
Competency of the firm’s Senior Managers
On 29 June 2022, the FCA conducted competency interviews with each of the firm’s proposed SMF 3 Sales Director, SMF 3 Chief Technical Officer and SMF 16 Risk and Compliance Director and assessed that the firm’s proposed SMF 3 Sales Director and SMF 16 Risk and Compliance Director were not demonstrating the required skills to hold the roles applied for. The firm confirmed that the SMF 3 Sales Director and SMF 16 Risk and Compliance Director held ultimate sign off on the firm’s sales processes, which the Authority assessed as being non- compliant.
The firm purchases data from one data vendor. The FCA believes that this practice is in breach of the provisions of FPCOB 6.5.2R, which bans funeral plan firms from receiving commission payments.
The FCA conducted a review of the sales calls conducted by the firm and had identified concerns, including agents not providing consumers with the full cost of plans prior to commencing the sales process, pressured sales, not assessing whether consumers already had a plan in place, non-disclosure of cancellation fees, overestimating the future cost of funerals, selling plans where the consumer required time to consider their options and not identifying vulnerability markers. These findings impact the firm’s ability to meet the Suitability threshold condition.
How can we help you?
If you’d like to know more about how we can help you with your funeral plan firm compliance arrangements, or any other regulatory compliance issues, our specialist team is here to help.