The Regulatory Committee discussed the FCA’s consultation on simplifying insurance rules. Members raised concerns about the lack of clarity around the definition of ‘bespoke’ business and the implications for open market and international placements. The proposed removal of the 12-month product review requirement was welcomed, though members noted the burden of justifying alternative review cycles. The FCA’s proposal for lead firms to assume full compliance responsibility prompted discussion on co-manufacturing agreements, governance roles and the absence of a formal MGA definition. 

The committee agreed to hold working group sessions and circulate a draft response. Updates were also shared on licensing developments in Brazil and Saudi Arabia, the LIC funds withheld agreement and the PBO workstream. Members were reminded to submit jurisdictional examples to support the FCA consultation.