CBI Updates 2022

Key dates

February 2022

- Fraudulent clone website www.seiinvestment.com deactivated following legitimate firm's report

26 September 2022

- CBI issues warning notice on SEI Investment clone

Suggested considerations

• Monitor for clones: Regularly search for impersonations of your firm's name, website, authorisation numbers, LEI, CRO, or address; report suspicions to CBI at (01) 224 4000.
• Client communications: Advise clients to always access CBI Register directly from www.centralbank.ie (not via email/website links), double-check URLs/phone numbers, verify products on legitimate sites, and apply the SAFE test for unsolicited contacts.
• Internal processes: Update fraud awareness training, client onboarding checks, and surveillance for clone activity; emulate SEI Investments by proactively notifying authorities.
• Public reporting: Encourage staff/clients to report unauthorised activity via CBI hotline or Search Unauthorised Firms page.

What changed

This is not a regulatory change or new requirement but a public enforcement warning under Section 53 of the Central Bank (Supervision and Enforcement) Act 2013, emphasising ongoing enforcement against unauthorised firms providing regulated financial services, which is a criminal offence. It reinforces consumer protection guidance without introducing new rules, but signals CBI's heightened focus on clone firm frauds, as seen in similar warnings (e.g., The Capital Holdings clone, Bank of Ireland clones).

Suggested considerations

• Pricing Adjustments: Update systems/models to ensure renewal prices ≤ EQFRP; identify close-matched products for comparisons.
• Conduct Reviews: Perform comprehensive annual review of pricing policies/processes, documenting compliance, controls, and rectifications; avoid "tick-box" approaches.
• Enhance Communications: Revise renewal notices/documents to include mandated info (e.g., price, cancellation rights, switching options); handle pre-1 July notices pragmatically but comply in spirit.
• Record Maintenance: Retain written records of reviews, pricing decisions, and compliance evidence for audit readiness.
• Internal Governance: Assess/align with CPC General Principle 2.1; monitor for material changes requiring documented consistency checks.

What changed

• - Ban on Price Walking: Insurance undertakings and intermediaries cannot charge renewing customers (defined as "relevant renewing customers") a premium higher than that charged to an equivalent...
• Annual Pricing Reviews: Firms must conduct an annual review of motor and home insurance pricing policies and processes within two months of each year-end to ensure compliance, including controls to...
• Automatic Renewal Disclosures: Firms must provide specific information to consumers before automatic renewals, including renewal price, right to cancel, and options to switch providers, to promote...
• Record-Keeping: Written records must be retained for annual reviews, material pricing decisions, and compliance assessments.
• Scope Exclusions: Applies prospectively from 1 July 2022; no retrospective application or transitional period.

Key dates

20 January 2022

Publication date of the three Behind the Data papers

Suggested considerations

• Review and enhance internal reporting on cross-border assets, distinguishing Irish-parent vs. foreign-parent activities, in anticipation of potential narrower CBI statistics.
• Map insurer fund exposures to underlying assets (e.g., equities, bonds) for geographic and asset-class transparency, addressing CBI-noted complexities in fund structures.
• Assess NBFI activities against FSB economic functions for stability risks; prepare for possible granular data requests.
• Monitor CBI's "Behind the Data" series for evolving trends, as it uses firm-submitted data and fulfills IMF recommendations (e.g., FSAP 2022 on fund exposures).

What changed

No direct regulatory changes, requirements, or new rules are introduced; these are analytical papers using existing locational banking, insurance, and fund data. Key insights include: (i) €180bn surge in cross-border bank assets (2018-Q3 2021) driven by UK-to-Ireland subsidiary migrations post-Brexit, concentrated in loans/deposits, derivatives, and three foreign-parent banks; (ii) Irish insurers' fund holdings primarily in equity (US-issued), bond (euro-area government/corporate), and mixed funds, with ~50% domiciled in Luxembourg but minimal local issuance; (iii) Recommendation for refined...