1. The length of registration is at the discretion of the Central Bank.
2. All licences for intermediaries will be granted for one (1) year only in the first instance.
3. Licence fees are to be paid annually regardless of the length of the period of registration granted.
4. Based on 1, 2 and 3 above a prorated period is not applicable for the payment of fees.

112 (2) An individual shall not be registered with more than one agency or insurer under the same class of insurance business at any particular time. Therefore, Yes. A sales representative can be contracted by an insurer for a class/type of insurance business and an agency for another class/type of insurance business.

112 (5) Where an individual wishes to be registered as a sales representative of more than one insurer or agency, provisions of Section 129 (3) shall apply mutatis mutandis and the individual shall make a separate application in respect of each insurer or agency.

See also the conditions under Section 129(3) – See page 213 of the IA, 2018.

1. If an Agency/Branch Manager has an Agency/Branch then that agency need to beincorporated and registered with the Central Bank.

2. The Agency then needs to have at least one (1) individual agent registered with the agency.

3. Sales representatives that represent the agency then needs to be registered with the Central Bank under that Agency for which they represent.

NOTE

(a) The Agent – defined as an individual employed by an agency to solicit applications for insurance or negotiate insurance on behalf of the agency;

(b) The Agency – defined as a company appointed by an insurer and registered under Part IV to carry on the business of an insurance agency, i.e., the company with which the insurer has the agency contract;

(c) The Sales Representative – defined as an individual who is contracted by the agency to
solicit applications for insurance or to negotiate insurance on behalf of that agency.

1. CPD is a requirement for sales representatives, agents and adjusters.

2. If the agency/branch manager is registered as one of the intermediaries in 1 above then they will have to fulfil the CPD requirements which includes the submission of annual returns.

3. Training done in the past is not considered CPD.

4. CPD is a continuous, on-going, structured requirement managed by the TTII for the purpose of ensuring that registered persons are knowledgeable and kept current in respect of the information required for the sale of insurance products.

This is a one-time request by the Central bank to ensure that all information in keeping with the new registration requirements under the Act for an intermediary is captured. This is a request for all classes of intermediaries.

No. This has been clarified in the new Act. An Agency is now defined as an incorporated body appointed by the insurer and registered with the Central Bank, while an agent is an individual that can only be contracted by an Agency.

1. CPD will commence 12 months after January 1, 2021 (commencement) which will be January 1, 2022. In accordance with Regulation 12 (4) of the Insurance (Intermediaries) Registration Regulations 2020.

2. During 2022 the relevant intermediaries are expected to complete 12 CPD hours in that CPD year.

3. In accordance with Regulation 14, intermediaries have until (or up to) the 12th month to complete, except those that are renewing before the 12th month. They will be required to complete the required CPD hours prior to the submission of their application for renewal.

NOTE

CPD Returns are due upon the intermediary’s renewal in 2022. As such, Intermediaries whose renewals are within the beginning of 2022 may be required to commence CPD activity after January 1, 2021, to ensure that 12 CPD hours are completed prior to their 2022 renewal.

1. Provisional licenses for sales representatives may be granted for up to three (3) years at the discretion of the Central Bank and based on reasonable criteria for not meeting the examination requirements similar to those stated in the question.

2. However, each application will be dealt with on a case by case basis on its own merit as renewal is not guaranteed under any circumstances.

1. The term financial advisor is at odds with the role and function of a sales representative by its definition.

2. Preferentially, persons should be advertised as sales representatives since the person is not registered with the Central Bank as a financial advisor.

3. Financial Advisors complete qualifications by an internationally recognized body and are involved in a more comprehensive view of a client’s situation to work towards their goals.

4. Agents and sales representatives are typically more focused on determining a client’s needs that their insurance products can address and on behalf of an insurer, brokerage or agency, whereas a financial advisor works on behalf of a client.

1. If Unit Managers function as employees of Insurance Companies in respect of training agents and sales representatives for different agencies, then it would be advisable that they registered as sales representatives of the insurer in order to ensure that they meet the minimum requirements of knowledge, education and continuous development in order to fulfil their duties.

2. If Unit Managers function as employees of the Agency then they should be registered as an agent or sales representative of the Agency for the same reasons as 1 above.