Underwriting Controls | Delegated Authority | Conduct Risk

Around the world, compliance regulations and expectations applicable to delegated authority are changing constantly. In the UK, ensuring fair customer outcomes (conduct risk), policy add-ons, financial promotions and renewal transparency are established. Newer focus is upon the roles, responsibilities and value of parties in the distribution chain.

JTW can help build these requirements into your company-wide processes and procedures

Strategy & Change Advisory

How do you integrate and embed corporate, service company, delegated authority strategies?

“Giving the pen away” – why, when and how?

How do you ensure board oversight, adequate MI and an internal control framework?

Can you unify and consistently deliver operational efficiencies across business units and departments?

Conduct Risk

Have do you ensure you have been fair, clear and transparent throughout the product lifecycle?

Do all parties in the distribution chain justify their role and commissions?

Are your claims, complaints and other MI sufficient for you to monitor customer outcomes effectively?

Is your customer focus truly embedded into your corporate culture – or hand on heart are you putting in procedures purely to satisfy regulators (such as the FCA, Lloyd’s, NAIC)?

Compliance & Contracts?

Based upon your risk assessment, what comfort do you need to obtain with regards to sanctions, financial crime, licensing, data security and GDPR?

Are your policies and wordings fair, clear and not misleading to your clients?

Do you conduct pre-bind quality assurance (PBQA) checks on your wordings?

Delegated Authority Underwriting

What are the pros and cons of “giving the pen away”?

Does a broker’s online platform accessible by agents make it a binding authority?

What’s the difference in practice between a lineslip and a consortium, between a master policy and an open cover?

How much due diligence do you need to do for each of the above?

The distribution Chain – Roles & Responsibilities

What are the legal and practical roles and responsibilities – to each other – of policyholders, retail brokers, wholesale brokers, coverholders, managing general agents, Lloyd’s brokers, Lloyd’s managing agents, insurance companies, reinsurance companies, reinsurers, regulators?

How should multiple roles and inherent conflicts of interest be managed?

Risk Assessments & Due Diligence

Perhaps you want to enter into a binding authority agreement with a coverholder or grant claims authority to a TPA.

Assessing risk – which is more important – customer type, class of business, location or level of delegation?

Is your risk assessment framework and due diligence approach joined up between underwriting, wordings, claims, compliance, credit risk, data capture, security & reporting?

Is your Delegated Authority Management department correctly structured and adequately resourced?

How often and with what scope do you need coverholder audits, TPA reviews, underwriter and claims visits?

Claims & TPA Management

How do you decide whether to retain claims authority, delegate to your coverholder, to a TPA, or a combination thereof?

What claims-related MI to you need to collate and how?

How are you ensuring fair customer outcomes throughout your processes and procedures?


Do you communicate management strategy and delegated authority requirements clearly and regularly to all of your internal stakeholders?

How about to your external brokers, TPAs, your clients and the regulators?

Are your marketing materials, due diligence request packs, partner guides and financial promotions all sufficiently concise, helpful, fair, clear and not misleading?

Doing Business Globally

Do you sufficiently recognize different practices and procedures for conduct risk and delegated business between the UK, mainland Europe, North America and the rest of the world?

How can you interpret regulatory expectations and legal differences across jurisdictions?

Do you approach your marketing, your business meetings and your social events in Tokyo as against New York, Madrid or London?

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