Earlier this week, the FCA published proposed guidance on its approach to Part VII insurance business transfers. It includes a detailed 'Review of the communications strategy' for firms and Independent Experts, which includes the following:

7.26      Any communications sent to Policyholders should include:

  • the IE’s report summary
  • a supporting document such as a Q&A or FAQ which gives further details and issues for note by Policyholders
  • a summary of the terms of the Scheme itself
  • a description of the effect of the main provisions

7.27      We also expect these attachments to be sent in full, rather than cross referred to as available online or on request, unless there are exceptional circumstances where a different approach is justified.


Does this signal a return to traditional longer mailings? It would seem so, and this would be in line with the general trend towards greater disclosure and transparency. But for many insurance companies with significant Policyholder databases, the cost of this – in both monetary terms and ‘green credentials’ (think of all those trees!) could be punitive. Around 40% of the world’s population uses the internet, and the number of users exceeds 3.5bn. Would a mix of email, online and printed mailings not be a sensible and realistic alternative?

Consultation closes on 15th August. Let the FCA know your views: PartVIIGuidancedocumentfeedback@fca.org.uk 


About us and Part VII Transfers

Black&Callow specialises in Project Managing the largest and most complex Part VII Transfers. For over 50 years we've cut our teeth on the largest and highest-profile transactions for banks and insurers and offer a greater range of services to help each transaction run smoothly.

We offer a broad range of solutions – from email, online and printed & mailing solutions - designed to provide the greatest flexibility, and all as a ‘one stop shop’ to ensure the shortest lines of communication, greater control and confidentiality. Our London City offices are always available for your team and advisers to draft documents and plan in comfort and convenience.

For more information visit http://blackandcallow.com/our-experience/part-vii-transfers/ or call us on 020 3794 1720.