Proposed legislation in the event of a No Deal Brexit will allow UK intermediaries to service Republic of Ireland customers to expiry date but will not allow UK intermediaries issue renewals or arrange new business with effect from 29th March 2019.
One of the solutions for UK brokers is a client transfer to a Republic of Ireland regulated intermediary. In this update we look at the practicalities of achieving this in the very limited window between now and 29th March 2019.
Central Bank of Ireland regulations require the current broker to communicate in writing with the clients, providing 60 days for them to opt out of a transfer to a named broker. Only when this period has expired can the customer details be transferred to the new broker. In effect this means if the initial communication was issued on 1st February the sixty day window would only expire on 31st March and effectively the new broker could only issue renewals from May onwards. If this process were to be followed a UK broker would find that they were unable to issue renewals for all customers with policies due in the period 30th March 2019 – 30th April 2019.
To overcome this a UK broker would need to request their customers (with renewal dates prior to 1st May 2019) to provide an opt in confirmation or mandate an alternative broker of their own choice. As a matter of best practise the current and proposed broker would both notify the Central Bank of Ireland on the intended transfer of business providing a copy of the customer communication letter for their review.
The prospect of a No Deal Brexit is now forcing UK brokers to take urgent action to ensure continuity of service to their Republic of Ireland based customers. As you can see from the timelines above, even by brokers taking action now, customers will need to make immediate decisions to ensure they will receive renewal terms in late March/April.
For further information on Brexit solutions from Campion Insurance contact:
(M) 00 353 87 1056747