Tips for brokers on complying with the 2022 Code of Practice

In mid-October, the IBCCC provided brokers with information about the 2022 Annual Compliance Statement (ACS) as the code requires them to self-report breach and complaints data from January 1 to December 31, 2022, and include thematic reference to both codes applicable during that period: the 2014 and 2022 codes. The statement also includes a questionnaire for brokers to share any challenges they have experienced transitioning from the 2014 code to the 2022 code.

However, the IBCCC noted that in some instances, code subscribers might struggle to fully comply with the new code of practice.

“For example, A code subscriber may have started training all its employees to support clients who experience vulnerability. However, by November 1, 2022, not all employees may have completed this training,” the IBCCC said. “The code subscriber should self-report this as a breach of obligations under section 5.2(c) of the 2022 Code in its 2022 ACS, as not all staff have been trained to support clients experiencing vulnerability. Detailed information should be provided, what caused the delay, any remediation action taken to rectify the breach, and an expected date by which all staff has been trained. This also provides management with an overview of any gaps in the transition and implementation process and where to focus additional resources.”

Read more: Insurance brokers not reporting code of practice complaints and breaches

The IBCCC further reminded code subscribers to inform it as soon as possible of any major compliance issues or queries they may have, so that the committee can track common code sections that may be more challenging to implement and provide any relevant guidance.

“The committee’s role is to work with the industry to deliver high-quality service to consumers and achieve better consumer outcomes,” it said. “We understand there are circumstances where subscribers are working towards full compliance.”

Commenting on the tip, NIBA reminded code subscribers to use the 2022 Breach Data Detail Report to track their progress in transitioning to the 2022 code.

“Subscribers are encouraged to report to the IBCCC any major compliance issues or queries as soon as they are identified. This will enable [the] committee to track any challenging sections of the code that may require further guidance,” NIBA added.