Address by Director of Consumer Protection, Bernard Sheridan, at the Insurance Institute Conferral of Insurance Qualifications Ceremony

I would like to thank the Insurance Institute for inviting me to your Conferral Ceremony here this evening.  When Eamon asked me to attend, I had no hesitation in accepting and, indeed, it is a pleasure for me to attend.  For the Central Bank of Ireland the whole area of the development of competencies and education standards among the providers of financial services is very important in helping us achieve our overall objectives of Safeguarding Stability and Protecting Consumers and achieving the right outcomes for consumers.

It is always important to take time to recognise the achievement of any professional standard and qualification.  From a personal perspective you can take a sense of pride in your achievement particularly when the qualification is so connected to your professional role and career.  We need to recognise the effort and sacrifices made by you in achieving a recognised standard which demonstrates your commitment to your career and to achieving a specific competency qualification.  As well as this personal achievement it also adds to the overall professionalism of the business in which you operate and the wider insurance sector.

From the Central Bank’s perspective the achievement of these professional standards and the role played by education bodies, such as the Insurance Institute of Ireland, play a critical part in delivering on our mission of getting it right for consumers.  For anyone dealing with consumers, experience on the job is certainly very important.  However, experience combined with a professional qualification, is a perfect combination in helping achieve the right outcomes for consumers.  It gives you that deeper knowledge and understanding and also the confidence that you are doing the right thing.

It is important that the consumer protection framework in Ireland is fit for purpose and achieving its objectives.  As you are aware, since Jan 1 2007, the Minimum Competency Code is a critical part of that framework as it underpins how financial products and services are delivered to consumers.  The Minimum Competency Code is an integral part of our Fitness & Probity regime which aims to ensure that persons providing financial services are competent and capable, act honestly, ethically and with integrity, and are financially sound.  Under the Minimum Competency Code responsibility is placed on all persons carrying out what we call controlled functions, as well as on the regulated firms themselves, to ensure that they meet the standards set out, both on entry to the financial services industry and also throughout their careers. By achieving this qualification you are deemed to be meeting these minimum standards. However, with this comes responsibility, to not only your employer but also to the consumers you will be dealing with. They will be relying on you to offer the best product or advice.

In February of this year, the Central Bank published its first Consumer Protection Outlook Report (and if you have not read it I would encourage you to have a look at it).  In the Outlook Report, we set out our key consumer protection objectives of working to ensure that firms are acting in the best interests of their customers and are treating them fairly and with dignity and respect.  The Outlook Report also sets out the risks we see to achieving those objectives and a number of areas we will be focussing on over the next few years. 

I would just like to briefly highlight three areas which are set out in the Outlook Report, under the 5 Cs framework we have, which I believe are directly relevant to your achievements.

Culture – the culture within any firm plays a very important part in how customers of that firm are treated.  Boards of directors and senior management set the tone from the top in terms of acceptable behaviours and priorities.  I believe it is important that these senior people continue to recognise the importance of supporting staff in achieving the right outcomes for consumers through education and on-going development and training.  This is one area where firms can demonstrate clearly that they have a customer focussed culture which is recognised and rewarded through supporting staff to achieve the highest standards.  It is also important that senior management are open to receiving feedback from front line staff who should have the confidence to challenge and speak up where you feel customers are not being dealt with appropriately and where the culture is not driving the right behaviours and delivering the right outcomes for consumers. 

The second C I would like to refer to is Confidence.  Achieving these qualifications should not only give you added confidence in your day-to-day work but hopefully will also encourage you to go even further with your education.  As consumers of products and services we expect that the people we are dealing with have the appropriate expertise and knowledge to to provide advice and services that meet our financial needs.  Dealing with someone who is qualified helps build that consumer confidence which should help them make the right decision.  On-going continuing professional development is a key part of the competency framework.  This gives you the opportunity to keep up to date with developments in the industry and which again should allow you to develop in your role. 

The third C I will end on is Compliance.  The Central Bank has been working with the education bodies over the last 10 years to build a minimum competency framework which delivers the right outcomes.  While it is a requirement now to meet these minimum standards in order to comply with the Central Bank’s fitness and probity standards, as we set out in the Outlook Report we expect firms to go beyond the minimum standards and to focus on the consumer outcomes rather than box ticking.  This also applies to competency standards.  Developing a wider understanding of the insurance market can only add to your ability to deliver in your role.  

In conclusion can I once again congratulate you on your achievements.  Clearly you have demonstrated your commitment to helping to deliver the right outcomes for consumers by achieving this standard.  My parting words to you are to go back to your own firms as ambassadors for consumer protection,  to use this qualification as a reminder of the responsibility you have to the consumers you will be dealing with and to use your influence to motivate those around you to work to the highest standards that we all as consumers expect.