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GIGI App 1 Appendix A: brief description of key terms in Part III

GIGI App 1.1G

Defined term


Client money

Money that a firm holds on behalf of a client in the course of carrying on insurance mediation activities. This includes money that a firm treats as client money in line with the FSA client money rules in CASS.

Contracts of large risks

A contract covering certain types of risks. These include ships or aircraft (and related liability), railway rolling stock and goods in transit, and credit and suretyship if the policyholder meets certain criteria. Property and liability risks are included as 'large risks' if the policyholder exceeds certain size thresholds.


In ICOB, a 'customer' is a policyholder or potential policyholder. This can include a member of a group policy who has direct rights under the contract of insurance, e.g. to claim.

In CASS, a 'customer' is the same as a 'client' who is any person with or for whom a firm conducts or intends to conduct designated investment business, insurance mediation or any other regulated activity.

Distance contract

A contract concluded without any face-to-face contact with the customer (e.g. by telephone, internet, e-mail or post).

Durable medium

In a form that a customer can keep and refer to as needed. It can include paper, disk, and e-mail.

Insurance intermediary

A firm carrying on insurance mediation activities. So as well as a broker it may be a bank, IFA or a retailer or an insurance company selling directly to the customer. For the purposes of this Guide we use it to mean a small insurance broker.

Insurance mediation activities

Any of the following regulated activities:

(1) dealing as agent in contracts of insurance;

(2) arranging (bringing about) deals in contracts of insurance;

(3) making arrangements with a view to transactions in contracts of insurance;

(4) assisting in the administration and performance of contracts of insurance;

(5) advising on contracts of insurance;

(6) agreeing to carry on any of the above activities.

Non-investment financial promotion

A financial promotion relating to a non-investment insurance contract that is not made in the course of a personal visit, telephone call or other interactive manner.

Non-investment insurance contract

A contract of insurance that is a general insurance contract or a pure protection contract but which is not a long-term care insurance contract.

Personal recommendation

A recommendation to a specific person (or group of people) on a non-investment insurance contract.

Retail and commercial customer

(1) A 'retail customer' is a customer who is an individual acting outside his trade business or profession.

(2) A 'commercial customer' is a customer who is not a 'retail customer'.