Applying for a permission

Insurance Manager

About

The purpose of this page is to make sure that the application process is fully understood.

This section sets out:

  • What an Insurance Manager is and what this regulated activity would allow you to do
  • Application Process
  • Capital Requirements
  • Additional Information

What is an Insurance Manager and what would this regulated activity allow you to do?

An Insurance Manager exercises managerial functions and/or;

• Gives advice;

• Offers to give advice; or

• Agrees to give advice in relation to an Insurance Company.

An Insurance Manager is authorised to exercise managerial functions in relation to the business of one or more Gibraltar-authorised Insurance or Reinsurance Companies.

 

Application Process

Following successful completion of the pre-application process, applicants should submit an application in line with the Staged Application for Authorisation Approach.

Initially, the applicant will only submit the Stage 1 application information - it is important that only Stage 1 information is provided at the outset of the application process.

The GFSC will communicate to the applicant that the application can progress to the next stage once the GFSC is satisfied with the content provided at the current stage. The applicant will then be invited to submit the further information required at the next stage of the application process.

Please request cloud access from the GFSC to submit the information requested, via e-mail to [email protected], stating in the subject field: ‘Name of Applicant – Application’.  Paper copies are not required unless indicated by the team.

Please note that we accept signed signature copies sent via e-mail and electronic signatures, which must originate from the Regulated Firm /Applicant’s domain.  

Stage 1 - Business Model, Capital & Key Individuals

The following is to be submitted for Stage 1: 

On receipt of the application fee and Stage 1 documents, the GFSC will confirm the GFSC Supervisor who has been assigned to assess the application for authorisation.

Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 1 will be communicated to the applicant during Stage 1.

When the GFSC is satisfied with all the responses and information/documentation received, the GFSC will inform the applicant that its application can progress to Stage 2.  

Stage 2 - Risk Management, IT Systems, Corporate Governance & Financial Crime

The following is to be submitted for Stage 2: 

  • Stage 2 of the General Comprehensive Business Plan (not including Stage 3);
  • Documentation and information including, but not limited to:
    • Corporate Governance and control
    • Business Continuity Management Plan
    • IT infrastructure, Cyber and systems including outsourcing arrangements
    • Operational & Outsourcing Risk including material outsourcing arrangements
    • Systems controls & Risk Management
    • Financial Crime controls, compliance with Anti-Money Laundering/Combating the Financing of Terrorism requirements (as applicable)
    • Risk Methodology and framework policy documents
    • Risk Register & controls
    • Disaster Recovery Plan 
    • Updated business plan, if required.

Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 2 will be communicated to the applicant during Stage 2.

When the GFSC is satisfied with all the responses and information/documentation received from an applicant, the GFSC will inform the applicant that its application can progress to Stage 3.

Stage 3 - Conduct of Business, Non-Financial Resource, Policies & Procedures

The following is to be submitted for Stage 3: 

  • Stage 3 of the General Comprehensive Business Plan;
  • Documentation and information including, but not limited to:
    • Non-financial resources
    • Compliance structure
    • Conduct of Business (Full Conduct Risk Framework documents)
    • Detail of KPIs
    • Consumer Duty compliance (as applicable)
    • Operational Resilience compliance (as applicable)
    • Remuneration Policy 
    • Conflict of Interest Policy
    • Conflict of Interest Register
    • Liquidity/solvency policies 
    • Internal Audit Plan 
    • Complaints Handling Policy 
    • Terms of Reference of the Board, Board sub-committees, Risk Committee and/or Audit Committee, Underwriting/Pricing committees, as applicable 
    • Audit, accounting, and banking arrangements 
    • Professional Indemnity Insurance 
    • Contracts with parties to whom material operational functions are outsourced 
    • Completed and signed Regulated Individual Forms and Non-Executive Director Forms
    • Mobilisation Plan (if applicable).

When the GFSC is satisfied with the Stage 3 responses and information, the application will move to a GFSC decision for authorisation.  

Capital Requirements

An Insurance Manger is required to hold an initial and ongoing capital of:

  1. £10,000; or
  2. The equivalent to one-third of the firm’s annual expenses (or as projected at application), whichever is the greater.

Regulated Firms holding multiple authorisations may be required to hold the aggregate of the capital required for each authorisation prior to conducting the proposed activity, and on an ongoing basis. In these cases, we will consider the level of capital. We advise that you discuss this with us ahead of your application.

 

Additional Information

Insurance Managers are required to hold on a permanent basis:

  • Professional Indemnity Insurance which guarantees against liability arising from professional negligence, for at least €1,000,000 (or sterling equivalent) applying to each claim and in aggregate €1,500,000 (or sterling equivalent) per year for all claims; and
  • At least two individuals as directors of the company to have the same skills, knowledge, experience, integrity and track record as if they were executive officers of the insurance or reinsurance companies under management.

The functions of an insurance manager are similar to the functions of the staff and executive team of an insurance company. Accordingly, we will consider applications for this type of authorisation in this context.

The insurance manager should advise how they intend to record all the information necessary to be able to prepare returns for its companies under management, such as management accounts and statutory accounts.

An insurance manager must enter into a formal agreement with the insurance company it proposes to manage. The Agreement should describe and direct the relationship between the parties and clearly set out their respective functions, duties and responsibilities.