ICOBS 6B.2 Setting renewal prices

Renewal price

ICOBS 6B.2.1R
  1. 1A firm must not set a renewal price that is higher than the equivalent new business price.

  2. Paragraph (1) applies at the point the renewal notice is prepared.

Combined home and motor insurance packages

ICOBS 6B.2.2R

1In the case of a combined home insurance and motor insurance package, the renewal price for each of the following must be no higher than the equivalent new business price:

  1. (1)

    the home insurance element;

  2. (2)

    the motor insurance element; and

  3. (3)

    the bundled price for the package.

Net-rated business

ICOBS 6B.2.3G

1ICOBS 6B.2.1R does not distinguish between firms writing gross-rated business or net-rated business. Insurers or managing agents writing net-rated business should apply the rules in this section to arrive at a net-rated price which is the equivalent new business price on a net-rated price basis.

Renewal price of retail premium finance

ICOBS 6B.2.4G

1Where a customer pays for their policy through retail premium finance, the renewal price of the policy should be set in accordance with ICOBS 6B.2.1R and the renewal price for the retail premium finance should be set in accordance with ICOBS 6B.2.37R.

Assumptions regarding channel used by customer

ICOBS 6B.2.5R
  1. (1)

    1In determining the equivalent new business price, a firm must assume that the existing customer has approached the firm through the same channel as they used when they first purchased their policy.

  2. (2)

    Where the firm no longer accepts new business through the channel that the customer originally used to purchase the policy, or where the channel can no longer be identified, the firm must assume that the customer approached the firm through the channel most commonly used by new business customers of the firm.

  3. (3)

    If the customer used more than one channel when they first purchased their policy, the firm must determine the equivalent new business price using the channel or combination of channels that was used to determine the price of the customer’s policy at new business.

ICOBS 6B.2.6G

1For the purposes of the assumptions in ICOBS 6B.2.5R, a firm should treat each intermediary chain, price comparison website or affinity/partnership scheme through which it sells policies as a separate channel.

ICOBS 6B.2.7R
  1. (1)

    1A firm may calculate the equivalent new business price on the basis that the customer is using a different channel than they used when they first purchased their policy where:

    1. (a)

      the customer has agreed to take out a different product to the one they took out in the last insurance period;

    2. (b)

      the product the customer is taking out is most frequently purchased via a different channel to the one the customer used to take out their original product; and

    3. (c)

      it is in the customer’s best interests to take out the new product.

  2. (2)

    Where a firm calculates the equivalent new business price according to (1), it must assume that the customer approached the firm using the channel that the product is most frequently purchased through.

Changing to a different policy with the same firm at renewal

ICOBS 6B.2.8G
  1. (1)

    1Where a firm offers a customer a different product at renewal the firm should be able to demonstrate how it has met:

    1. (a)

      the rules in ICOBS 5.2 (Demands and needs); and

    2. (b)

      ICOBS 2.5.-1R (customer best interests).

  2. (2)

    Firms are reminded that ICOBS 5.2 includes requirements for a firm, before conclusion of any contract of insurance, to

    1. (a)

      specify, on the basis of information obtained from the customer, the demands and needs of the customer; and

    2. (b)

      ensure that any contract of insurance proposed is consistent with the customer’s insurance demands and needs.

    Before proposing a different product at renewal, a firm will need to take all necessary steps to meet these requirements which may include contacting the customer and obtaining all necessary information from that customer so the firm can conduct a demands and needs assessment.

  3. (3)

    A firm should not offer or propose a different product to the customer at renewal if:

    1. (a)

      the different product is more commonly distributed through a more expensive channel than the channel or channels the customer originally approached the firm through; and

    2. (b)

      the primary purpose of distributing the alternative product is to enable the firm to charge the customer a higher renewal price.

Incentives

ICOBS 6B.2.9R

1When calculating the equivalent new business price, a firm must include any cash or cash-equivalent incentives that it gives to new business customers and that the renewing customer would be eligible for if they were a new business customer.

ICOBS 6B.2.10R
  1. (1)

    1ICOBS 6B.2.9R applies to any cash or cash-equivalent incentive that is wholly or partially funded by the firm.

  2. (2)

    For the purposes of (1), it does not matter if the incentive is funded directly by the firm or if the firm provides funding to a third party contingent on that third party providing an incentive to the customer.

ICOBS 6B.2.11R

1Incentives that are not cash or cash-equivalent are excluded from the scope of these rules.

ICOBS 6B.2.12R

1A cash or cash-equivalent incentive is any incentive that can be readily expressed as having a monetary value including, but not limited to, the items listed in column 1 of the table at ICOBS 6B.2.14R.

ICOBS 6B.2.13R

1Non-cash incentives are any incentives that are not capable of being readily expressed as having a definite monetary value.

ICOBS 6B.2.14R

1The following table gives examples of cash and non-cash incentives for the purposes of ICOBS 6B.2.12R and ICOBS 6B.2.13R.

Cash or cash-equivalent incentives

Non-cash incentives

A percentage discount on the premium

Toys

A monetary discount on the premium

Carbon off-setting

Part of the insurance term given for free (e.g. one month free)

A percentage chance to win back the premium

A free additional product

Cashback

Retail vouchers

Points in a retail loyalty scheme

ICOBS 6B.2.15G

1Firms are reminded that Principle 7 and ICOBS 2.2.2R apply to the communication of incentives in the same way as they apply to all communications with their customers. Firms should present incentives in a way that makes clear both the overall price of the product, not including the incentive, and (if different) the price the customer will actually pay.

New business discounts

ICOBS 6B.2.16R

1The equivalent new business price must take account of any individually negotiated discounts the firm agrees with an equivalent new business customer for the product.

ICOBS 6B.2.17G

1In taking account of individually negotiated discounts agreed with new business customers, a firm should be able to demonstrate that:

  1. (1)

    the equivalent new business price does not discriminate on grounds of tenure contrary to ICOBS 6B.2.40R; and

  2. (2)

    the firm has taken account of the best interests of its customers (ICOBS 2.5.-1R) in determining its method for calculating the equivalent new business price in compliance with ICOBS 6B.2.16R.

Calculating the equivalent new business price - missing information

ICOBS 6B.2.18G
  1. (1)

    1Where a firm does not have the same information for an existing customer as it has when quoting for a new business customer, it may determine its own approach to how it takes account of any missing information when calculating the equivalent new business price.

  2. (2)

    Examples of situations where a firm may have missing information when calculating the equivalent new business price are:

    1. (a)

      where the firm uses behavioural factors in calculating the price a new business customer pays, such as the length of time between the quote and the inception date; and

    2. (b)

      where a firm has changed the information it obtains from new business customers when providing a quote.

  3. (3)

    Firms are reminded that where factors such as those described in (2) are taken into account in determining the renewal price, they must still be able to demonstrate compliance with:

    1. (a)

      the requirement to not discriminate on grounds of tenure in ICOBS 6B.2.40R; and

    2. (b)

      the requirements to provide fair value in relation to non-investment insurance contracts in PROD 4.2.14AR and, where relevant, PROD 4.2.14BR.

Calculating the equivalent new business price - information acquired during the term of the customer’s current policy

ICOBS 6B.2.19R
  1. (1)

    1A firm must include in its determination of a customer’s equivalent new business price any risk information acquired during the term of the customer’s current policy that has the effect of either increasing or decreasing the equivalent new business price.

  2. (2)

    Paragraph (1) includes risk information that the firm would not normally have in relation to new business customers, such as telematics data or fraud risk indicators.

Changes to contractual parties

ICOBS 6B.2.20 G

1A firm only needs to comply with the rules in this chapter where it arranged the contract or was a party to the contract with the customer in the previous year. For example, where an intermediary operates a panel of insurers and re-brokes the customer’s insurance to another member of the panel, the customer should be treated as a renewal by the intermediary but a new business customer by the insurer who did not underwrite the customer’s policy in the previous year.

Subscription policies

ICOBS 6B.2.21R

1Where a firm increases the price of a policy sold on a subscription basis, it must apply the rules in this chapter on setting a renewal price.

ICOBS 6B.2.22R

1A firm that sells policies on a subscription basis must review the pricing of their subscription policies at least annually.

ICOBS 6B.2.23R

1The annual review must assess whether the price of the policy sold on a subscription basis is no higher than the equivalent new business price.

ICOBS 6B.2.24G

1The rules in this chapter do not require a firm selling policies on a subscription basis to back date any price reductions that the firm may implement as the result of any review under ICOBS 6B.2.21R.

Closed books

ICOBS 6B.2.25R

1Where a customer’s policy is in a closed book, the firm must determine the customer’s equivalent new business price according to the following rules.

ICOBS 6B.2.26R

1The firm must identify from the home insurance and motor insurance products that it currently actively markets or distributes, whether it has a home insurance or motor insurance product that is a close matched product.

ICOBS 6B.2.27R

1Where the firm no longer actively markets or distributes any home insurance or motor insurance product which is a close matched product but it is part of a group which does actively market or distribute home insurance or motor insurance products, it must identify whether the firm’s group actively markets or distributes a close matched product.

ICOBS 6B.2.28R

1Where there is more than one product which is a close matched product, the firm must select:

  1. (1)

    the close matched product which is the most similar to the customer’s existing policy; or

  2. (2)

    where it is not possible to identify the most similar close matched product, the close matched product which will lead to the most favourable pricing outcome for customers who hold a policy in the closed book.

ICOBS 6B.2.29R

1Where a close matched product is identified or selected, the equivalent new business price for a customer in the relevant book is the price set out in (1), taking account of the permitted adjustments set out in (2) below.

  1. (1)

    The equivalent new business price for the close matched product.

  2. (2)

    The permitted adjustments are those which fairly and proportionately reflect the difference in costs for the firm arising from differences between the cover or benefits (including any compulsory excess) or other costs of providing services or benefits under the contract (such as additional telephone support) provided by the policies in the closed book and the close matched product.

ICOBS 6B.2.30R

1In calculating the equivalent new business price for a close matched product, a firm must assume that the customer approached the firm using the channel most commonly used by new business customers of the close matched product.

ICOBS 6B.2.31R

1A firm must set the renewal price in accordance with ICOBS 6B.2.39R if either (1) or (2) apply:

  1. (1)

    the firm is unable to identify a product which is a close matched product; or

  2. (2)

    the firm is unable to determine an equivalent new business price because the firm would not offer a policy to a new business customer of the same risk profile as the existing customer.

ICOBS 6B.2.32R

1A firm must assess whether any of its home insurance or motor insurance products are in closed books:

  1. (1)

    at least annually; and

  2. (2)

    whenever the firm makes a material change to the distribution or marketing of the product that could change the book from being an open book to a closed book.

ICOBS 6B.2.33G
  1. (1)

    1The calculation of whether a book meets the closed book definition should be carried out on the basis of the product as a whole across all the channels used by the firm for distribution of the product.

  2. (2)

    A firm should apply the definition on the basis of its own book of business, without reference to other firms involved in distributing or underwriting the product. This means:

    1. (a)

      an insurer should apply the closed book definition only to those products that it underwrites; and

    2. (b)

      an insurance intermediary should apply the closed book definition only to those products which it has distributed.

Intermediaries’ remuneration and involvement in setting price

ICOBS 6B.2.34R

1An insurance intermediary that is involved in the setting of any portion of the renewal price of the policy must ensure that the portion they set or their contribution to that portion is set at a level that is no higher than it would be set for a new business customer.

ICOBS 6B.2.35R

1An insurance intermediary that carries out insurance distribution activities at renewal and which either:2

  1. (1)

    forgoes commission in whole or in part when selling to new business customers; or

  2. (2)

    offers a cash or cash-equivalent incentive (within the meaning of ICOBS 6B.2.12R) to new business customers,

must, to the extent that a customer renewing a policy would be eligible to benefit from the commission forgone or the cash or cash-equivalent incentive if they were a new business customer, include that forgone commission or cash or cash-equivalent incentive when:

  1. (1) determining the equivalent new business price at renewal; and

  2. (2) applying ICOBS 6B.2.9R to ICOBS 6B.2.15G.

Additional products

ICOBS 6B.2.36R

1A firm that has responsibility for setting the price of an additional product that is available to a customer in connection with a home insurance or motor insurance policy must ensure that the price of the additional product at renewal is no higher than the price at which the additional product would be offered to the customer if they were a new business customer.

ICOBS 6B.2.37G

1Where the additional product is retail premium finance, the price referred to in ICOBS 6B.2.36R is the APR if the retail premium finance is a regulated credit agreement or in all other cases the amount paid by the customer for retail premium finance for the amount of premium to be financed by the retail premium finance.

ICOBS 6B.2.38R

1Where a firm no longer offers to new business customers an additional product which is available to a customer in connection with the renewal of a home insurance or motor insurance policy, the price for that additional product must be set as follows:

  1. (1)

    where the additional product is a policy, the firm must:

    1. (a)

      apply the rules for closed books in ICOBS 6B.2.25R to ICOBS 6B.2.33G (and references in these rules to home insurance or motor insurance should be read as ‘additional product’); or

    2. (b)

      if the additional product has no close matched product, apply ICOBS 6B.2.39R;

  2. (2)

    where the additional product is not a policy, the firm must apply ICOBS 6B.2.39R.

Firms’ assurance over customer outcomes

ICOBS 6B.2.39R

1A firm must ensure that it does not systematically discriminate against customers based on their tenure, when determining:

  1. (1)

    an equivalent new business price;

  2. (2)

    the renewal price for customers in closed books where a firm is unable to identify a close matched product;

  3. (3)

    the price for any additional products offered to the customer at renewal of a policy; and

  4. (4)

    the level of any remuneration earned by the firm, including in particular any fees charged to a customer, at renewal of a policy.

ICOBS 6B.2.40E
  1. (1)

    1A firm’s equivalent new business price for customers of longer tenure should not systematically exceed the new business price for new business customers.

  2. (2)

    A pricing model used by the firm to determine the equivalent new business price, or renewal prices for customers in closed books where a firm is unable to identify a close matched product, should not generate prices which are systematically higher the longer a customer’s tenure is.

  3. (3)

    A firm’s renewal price for customers of longer tenure, or the price for any additional products offered to customers of longer tenure at renewal of a policy, should offer fair value to the customer taking account of the prices offered to customers of shorter tenure. In particular, a firm should avoid the following outcomes:

    1. (a)

      the price of any of the following materially exceeding the new business price which a customer of longer tenure would pay to obtain the cover and/or benefits offered by the product if the customer were to shop around as a new business customer approaching another firm or firms:

      1. (i)

        the firm’s renewal price for customers in a closed book where no close matched product is identified;

      2. (ii)

        the firm’s price for any additional product offered at renewal where that additional product is a policy and no close matched product is identified; or

      3. (iii)

        the firm’s price for any additional products offered at renewal where the additional product is not a policy and is no longer available to new business customers;

    2. (b)

      the quality of service or cover enjoyed by customers of longer tenure is lower than that enjoyed by customers of shorter tenure for the same product; and

    3. (c)

      relevant and appropriate value measures, or the gross incurred claims ratio, for policies held by customers of longer tenure indicate that the value provided by these policies is lower than that for policies held by customers of shorter tenure.

  4. (4)

    A firm should not systematically charge higher fees to a customer who is renewing a policy than to a new business customer.

  5. (5)

    A firm should not selectively close individual channels in order to take advantage of the premium difference between channels when setting an equivalent new business price.

  6. (6)

    A firm should not fund an incentive offered by a third party in a way that results in the equivalent new business price systematically exceeding the new business price actually paid by new business customers who receive the incentive.

  7. (7)

    Contravention of any of (1) to (6) may be relied on as tending to establish contravention of ICOBS 6B.2.39R.

ICOBS 6B.2.41G

1When comparing a firm’s new business price with the renewal price for individual customers, we would not expect to see that the longer a customer’s tenure is, the greater the difference between:

  1. (1)

    in the case of an insurer, the risk price and the net-rated price or gross price; or

  2. (2)

    in the case of an intermediary, the net-rated price and the gross price.

ICOBS 6B.2.42R

1A firm must not make arrangements that are designed to enable it to treat existing customers as new business customers unless:

  1. (1)

    the firm can demonstrate that the proposed arrangements are in the best interests of the customers that will be treated as new business customers under the arrangements; and

  2. (2)

    the price of the products distributed to these customers does not adversely impact on the product offering fair value according to PROD 4.2.14AR and, where relevant, PROD 4.2.14BR.

ICOBS 6B.2.43E

1A firm should not participate in or carry out any of the following steps where the primary impact on existing customers affected by the steps is to increase the price these customers pay for their product:

  1. (1)

    establish a new entity or entities (whether this is done by the firm or a member of its group) that will be responsible for arranging polices for existing customers at renewal;

  2. (2)

    transfer the business of existing customers to existing entities in the group or existing subsidiaries; and

  3. (3)

    sell to existing customers at renewal a product that is only superficially different from the customer’s current product.

Contravention of any of (1) to (3) may be relied upon as tending to establish contravention of ICOBS 6B.2.42R and ICOBS 2.5.-1R.

ICOBS 6B.2.44R

1It is not a contravention of ICOBS 6B.2.39R or ICOBS 2.5.-1R for a firm to offer a customer a renewal price that is lower than the equivalent new business price based on any factor, including the customer’s tenure.

Notifications to the FCA

ICOBS 6B.2.45R

1A firm must notify the FCA if it becomes aware that any other firm in the distribution chain is not or may not be complying with the rules in this chapter.

ICOBS 6B.2.46G

1Under Principle 11, firms should notify the FCA of any change in their pricing model where there is a material risk of harm for customers.

Sales practices

ICOBS 6B.2.47R

1When communicating a renewal price to customers, or when contacted by customers to discuss a renewal price, a firm must not systematically discriminate against customers based on tenure.

ICOBS 6B.2.48R

1When communicating a price for any additional product at renewal of the policy, or when contacted by customers to discuss the prices of additional products at renewal of their policy, a firm must not systematically discriminate against customers based on tenure.

ICOBS 6B.2.49E
  1. (1)

    1A firm should not communicate with a customer of longer tenure in a manner which is objectively likely to discourage a customer of longer tenure from shopping around for an alternative policy offered by another firm.

  2. (2)

    A firm should not communicate with customers of longer tenure with the intent, or in a way that might reasonably be expected to have the effect, that these customers are less likely than other customers to contact the firm to negotiate the renewal price of the policy.

  3. (3)

    A firm should not interact with customers of longer tenure with the intent or the effect that these customers are more likely than other customers to accept the renewal price of the policy.

  4. (4)

    Contravention of any of (1) to (3) may be relied on as tending to establish contravention of ICOBS 6B.2.47R or ICOBS 6B.2.48R.

ICOBS 6B.2.50G

1Where a firm has communicated a renewal price to a customer in compliance with the rules in this chapter, a firm may subsequently agree a discount to a renewal price in individual negotiations with the customer.

Records

ICOBS 6B.2.51R

1A firm must make and retain written records of how it continues to satisfy itself that it does not systematically discriminate against customers based on tenure in contravention of ICOBS 6B.2.39R including details of:

  1. (1)

    the assessment undertaken by the firm to evaluate whether the equivalent new business price for3 customers of longer tenure systematically exceeds that for new business customers;

  2. (2)

    the controls put in place by the firm to ensure that any pricing model it uses to generate its equivalent new business prices, or the renewal prices for customers in closed books where a firm is unable to identify a close matched product, does not generate prices which are systematically higher the longer a customer’s tenure is;

  3. (3)

    the evidence gathered and the assessment undertaken by the firm to evaluate whether its renewal prices or prices for additional products at renewal offer fair value to customers of longer tenure;

  4. (4)

    the assessment undertaken by the firm to evaluate whether the fees it charges to customers of longer tenure systematically exceed those charged to new business customers; and

  5. (5)

    any appropriate independent oversight of the assessments and controls in (1), (2), (3) and (4).

ICOBS 6B.2.52R

1A firm must make and retain written records of how it satisfies itself that any arrangements it makes to enable it to treat existing customers as new business customers are consistent with ICOBS 6B.2.39R, including details of:

  1. (1)

    the assessment it has undertaken to assure itself that the customer best interests rule in ICOBS 2.5.-1R is met; and

  2. (2)

    the assessment it has undertaken of the likely effect of the arrangements on the price customers will pay for their product after the arrangements have taken effect as compared to the price customers would pay if the arrangements did not take effect.

ICOBS 6B.2.53R

1A firm must also make and retain written records of its consideration of the extent to which material decisions which it takes in relation to its compliance with the rules in this chapter are consistent with:

  1. (1)

    the objectives of these rules as set out in ICOBS 6B.1.4G3;

  2. (2)

    the requirement not to discriminate against customers based on tenure in ICOBS 6B.2.39R, ICOBS 6B.2.47R and ICOBS 6B.2.48R; and

  3. (3)

    the requirements in ICOBS 6B.2.42R around making arrangements to treat existing customers as new business customers.

ICOBS 6B.2.54R

1The records in ICOBS 6B.2.51R and3 ICOBS 6B.2.52R must set out clearly:

  1. (1)

    the basis on which the firm is complying with the rules in this chapter;

  2. (2)

    how the firm has resolved any areas of discretion, ambiguity or potential uncertainty in its determination that the pricing of its home insurance and motor insurance renewal business, including additional products available to customers in connection with this business, is in compliance with the rules in this chapter; and

  3. (3)

    appropriate expert input and advice on which the firm relies in satisfying itself as to its compliance with the rules in this chapter.

ICOBS 6B.2.55G

1The material decisions referred to in ICOBS 6B.2.53R include, but are not limited, to:

  1. (1)

    launching, discontinuing or materially varying any aspect of a product which is, or could be, relevant to setting an equivalent new business price;

  2. (2)

    taking action which would result in a book becoming a closed book for the purposes of the rules in this chapter;

  3. (3)

    identifying or selecting a close matched product or determining that it is not possible to identify a close matched product;

  4. (4)

    making any adjustments to the equivalent new business price for a close matched product as a result of applying the assumptions in ICOBS 6B.2.29R and ICOBS 6B.2.30R;

  5. (5)

    making changes to the firm’s business structure or to the business structure of a firm’s group to the extent that this may affect the basis on which an equivalent new business price is set;

  6. (6)

    determining the firm’s approach to ensuring that it does not systematically discriminate against customers based on their tenure in accordance with ICOBS 6B.2.39R, ICOBS 6B.2.43R and ICOBS 6B.2.44R; and

  7. (7)

    arranging for another entity or entities to offer the renewal product to the customer.

ICOBS 6B.2.56G
  1. (1)

    1The following are examples of the types of records that firms should retain under ICOBS 6B.2.51R to ICOBS 6B.2.53R:

    1. (a)

      records of minutes of any pricing committee;

    2. (b)

      any analysis showing whether similar customers face different pricing outcomes;

    3. (c)

      where the firm’s data indicates any potential issues under ICOBS 6B.2.40R, any analysis demonstrating that the firm has not discriminated against customers of longer tenure.

ICOBS 6B.2.57R

1The records compiled by the firm in accordance with ICOBS 6B.2.51R to ICOBS 6B.2.53R must be provided as soon as reasonably practicable after the record is prepared or updated to the person responsible for the attestation in ICOBS 6B.2.60R, and to the FCA on request.

ICOBS 6B.2.58G

1Firms are reminded of their obligations under SYSC 3.2.20R and SYSC 9.1.1R in relation to the keeping of records and the guidance in SYSC 3.2.21G and SYSC 9.1.5G regarding the nature of the systems and controls a firm should have in place and the general principle that records should be retained for as long as is relevant for the purposes for which they are made.

Policies and procedures

ICOBS 6B.2.59G

1A firm should have in place policies and procedures to ensure its ongoing compliance with the rules in this chapter following any material changes to the firm’s pricing practices, pricing models or products which could affect a firm’s compliance with rules in this chapter or fair outcomes for customers of longer tenure.

Attestation requirements

ICOBS 6B.2.60R

1Every firm subject to the rules in this chapter must provide the attestation set out at (1) for the reporting period set out in (2) at the time set out in (3) by a person in (4) below.

  1. (1)

    The attestation is that the firm:

    1. (a)

      is and has been complying with the rules in this chapter throughout the reporting period; and

    2. (b)

      is satisfied that the pricing of its home insurance and motor insurance renewal business and related sales practices are consistent with the objectives of the rules as set out in ICOBS 6B.1.4G and does not discriminate against customers of longer tenure as set out in ICOBS 6B.2.39R, ICOBS 6B.2.47R and ICOBS 6B.2.48R.

  2. (2)

    The reporting period is the 12-month period beginning 1 January and ending 31 December.

  3. (3)

    The attestation must be provided annually, on or before 31 March in the year following the end of the reporting period.

  4. (4)

    The attestation must be provided by:

    1. (a)

      a single person, who holds a senior management function in the firm; or

    2. (b)

      where a firm is not an SMCR firm, by a director of the firm.

Format and method of submission of attestation

ICOBS 6B.2.61R

1The attestation must be submitted online through the appropriate systems accessible from the FCA’s website.

ICOBS 6B.2.62R

1The attestation will not be considered as submitted to the FCA unless it has been accepted by the relevant FCA system.

ICOBS 6B.2.63G

1If the FCA’s information technology systems fail and online submission is unavailable for 24 hours or more, the FCA will endeavour to publish a notice on its website confirming that online submission is unavailable and will confirm what methods of submission should be used instead.