FCA and PRA Regulatory Objectives Explained
FCA and PRA Regulatory Objectives Explained
The Financial Conduct Authority (FCA) has a single strategic objective and three operational objectives.
Which of the following is NOT one of the three operational objectives?
The FCA's Principles for Businesses (PRIN) contains 12 principles. Which of the following Principles is
applied by the FCA but is NOT applied by the Prudential Regulation Authority (PRA)?
The FCA's Consumer Duty (Principle 12) requires firms to act to deliver good outcomes for retail customers.
In which of the following scenarios would an underwriting decision most likely NOT be subject to the
Consumer Duty?
The Prudential Regulation Authority (PRA) divides firms into four categories based on their 'potential
impact' if they fail. What is the defining characteristic of a Category 1 firm?
A) Firms that have the capacity to cause some disruption to the UK financial system.
B) Firms whose failure could cause minor disruption, but whose sector difficulties could generate broader
disruption.
C) Firms whose size, interconnectedness, complexity, and business type give them the capacity to cause very
significant disruption to the UK financial system by failing.
D) Firms that have almost no capacity to cause disruption individually but whose sector difficulties have the
potential to generate disruption.
A consumer holds a combined general insurance policy for their home and contents, which includes a
compulsory component of Employers' Liability (EL) cover for a domestic cleaner. If the insurer fails, what
are the respective compensation limits for the General Insurance (GI) portion and the Employers' Liability
(EL) portion under the Financial Services Compensation Scheme (FSCS)?
A) GI: 90% of the claim (no upper limit); EL: 90% of the claim (no upper limit).
B) GI: 90% of the claim (no upper limit); EL: 100% of the claim (no upper limit).
C) GI: 100% of the claim (no upper limit); EL: 90% of the claim (no upper limit).
D) GI: £85,000 limit; EL: 100% of the claim (no upper limit).
Which statement accurately reflects the differing regulatory focus for dual-regulated insurance companies?
A) The PRA seeks to ensure policyholders are treated fairly; the FCA seeks to ensure continuity of policy
provision.
B) The PRA is concerned with the safety and soundness of the UK financial system; the FCA is concerned
with ensuring policyholders are treated fairly.
C) The PRA ensures continuity of policy provision; the FCA ensures the firm maintains adequate financial
resources.
D) The PRA is responsible for the conduct of business; the FCA is responsible for prudential regulation.
A) Where the insurer has breached the terms of a statute such as the Equality Act 2010.
C) Where the underwriting decision is deemed to be against the firm’s proper use of commercial judgment.
D) Where the underwriting decision is found to have breached the firm’s own internal complaints procedure.
An insurance broker is found to be consistently selling inappropriate add-on products to its customers. The
FCA initiates a fast, intensive campaign to review this practice across the entire intermediary sector. This
action aligns with which pillar of the FCA's supervision model?
B) Event-driven work.
C) Thematic Review.
A complainant is referred to the Financial Ombudsman Service (FOS) concerning an issue that occurred five
years ago. Which combination of scenarios would allow the FOS to consider the complaint?
A) The firm's final response letter was issued seven months ago, and the complainant only knew of the cause
for complaint four years ago.
B) The firm's final response letter was issued five months ago, and the complainant only knew of the cause
for complaint four years ago.
C) The firm’s final response letter was issued seven months ago, but the case involves a pension transfer.
D) The event occurred over six years ago, but the firm has given its agreement to the FOS to review the case.
An underwriter is creating a complex insurance scheme for a new product, which involves a referral process
where the underwriter provides suitability advice based on the client's information. Which Principle for
Businesses (PRIN) is this underwriter most closely impacting by ensuring the advice provided is appropriate
for the client?
A) Principle 6: Customers' interests.
Answer
Question 1
C) To promote the safety and soundness of the firms it regulates. This is the general objective of the
Prudential Regulation Authority (PRA). The FCA's strategic objective is "to ensure that the relevant
markets function well". Its three operational objectives are A, B, and D.
Question 2
D) Principle 6: Customers' interests. The PRA only applies Principles 1 to 4, 8, and 11. Principle 6, which
requires a firm to pay due regard to the interests of its customers and treat them fairly, is a conduct
regulation principle falling solely under the FCA's remit for dual-regulated firms.
Question 3
C) A contract of reinsurance accepted from an overseas cedant. The Consumer Duty does not apply to
reinsurance. It also does not apply to contracts of large risk sold to commercial customers, or activities
connected to the distribution or extension of group insurance policies to new members. Although D is
related to an exclusion, the most definitive and distinct exclusion from the options is C.
Question 4
C) Firms whose size, interconnectedness, complexity, and business type give them the capacity to cause
very significant disruption to the UK financial system by failing. This is the explicit definition of a
Category 1 firm, representing the highest risk to the PRA's objectives.
Question 5
B) GI: 90% of the claim (no upper limit); EL: 100% of the claim (no upper limit). General insurance
(excluding compulsory and protection-based policies) is covered at 90% with no upper limit. Compulsory
insurance, such as Employers' Liability, is covered at 100% with no upper limit.
Question 6
B) The PRA is concerned with the safety and soundness of the UK financial system; the FCA is
concerned with ensuring policyholders are treated fairly. The PRA seeks to ensure continuity of policy
provision (a component of safety and soundness) , while the FCA seeks to ensure policyholders are treated
fairly (conduct regulation). Option C inverts the roles. Option B is incorrect as the FCA focuses on conduct,
while Principle 4 (Financial prudence) is a shared principle applied by both, but prudential regulation is
primarily the PRA's role. Option D inverts the roles.
Question 7
A) Where the insurer has breached the terms of a statute such as the Equality Act 2010. The FOS is
generally unable to rule on underwriting decisions as they relate to 'a business's proper use of its commercial
judgment'. An exception is made where the insurer has breached a statute like the Rehabilitation of Offenders
Act 1974 or the Equality Act 2010. Option A is ineligible as the income limit for charities is less than £6.5m.
Question 8
D) Issues and products. This pillar focuses on "Fast, intensive campaigns on sectors of the market or
products within a sector that are putting or may put consumers at risk". The FSF is preventative work
focusing on a firm's governance and culture , while event-driven work deals with emerging or occurred
problems. A thematic review is the method used to carry out the work, but 'Issues and products' is the
designated pillar name.
Question 9
B) The firm's final response letter was issued five months ago, and the complainant only knew of the
cause for complaint four years ago. The complaint must be referred to the FOS within the earliest of:
1. Six months of the firm’s final decision letter. (Five months is within the limit.)
2. Six years after the event. (Five years is within the limit.)
Three years after the complainant knew, or should have known, that they had cause for complaint. (Four
years exceeds the limit, but the FOS uses the earliest of the time limits as a trigger for being time-barred.
The text suggests that the complaint will be time-barred if any of the limits are passed, but the actual FOS
rule is that the firm can object if the complaint is time-barred by any of the rules, and the FOS will check.
However, comparing the options, B is the only one where both the 6-month and 6-year deadlines are
respected. Option C and D deal with exceptions but D is the more definitive exception: the firm can agree to
waive the time bar even if the six-year limit has expired. Correction: Re-evaluating B vs D for "hardest"
and most technically correct. Option D: The six-year limit has expired (event over six years ago), but the
firm agrees to review. This is explicitly stated as an allowance. Option B: 5 months (OK), 5 years (OK), 4
years (over 3 years limit). The firm can object to a time-barred complaint. Therefore, D is the scenario most
likely to proceed, as it involves the firm overriding the bar. For the purpose of a hard exam question, B is the
best distractor as it tests multiple time limits, and is the technically time-barred option among the non-
exception cases. However, since the question asks for a scenario that allows the FOS to consider the
complaint, and Option D involves a permissible exception, D is the most robust correct answer by way of
exception. Let's choose the exception-based answer for a challenging question.
Question 10
D) Principle 9: Customers: relationships of trust. This principle specifically requires a firm to "take
reasonable care to ensure the suitability of its advice and discretionary decisions for any customer who is
entitled to rely upon its judgment". While all options are relevant conduct principles, Principle 9 is the
precise principle relating to suitability of advice.
Chapter 2
Capital and Solvency Requirements
An insurer's investors require a minimum return of 10% on their allocated capital (assets). Given the
following portfolio data, what is the required % return (profit) on premium for the Employers' Liability
account and the Household account, respectively?
Which regulatory requirement represents the greater of the Minimum Capital Requirement (MCR) and the
risk-based calculation known as the Enhanced Capital Requirement (ECR)?
Following the transition to Solvency UK, what is the new minimum gross written premium threshold for
firms to which Solvency UK applies?
A) €5 million or more
Which of the following was NOT a key objective of the original EU Solvency II Directive?
C) To improve consumer protection by ensuring a uniform and enhanced level of policyholder protection.
D) To simplify the calculation of the Transitional Measure on Technical Provisions (TMTP). (This was a
change under Solvency UK, not an original Solvency II objective.)
Liability accounts require a greater allocation of capital compared to property accounts primarily because of
volatility. How does the chapter define volatility in this context?
A) The possibility that the investment returns on reserves will not match expectations.
B) The total value of all claims in a portfolio exceeding the total premium income.
C) The fact that a small but significant minority of liability claims can be particularly expensive and less
certain to settle in value and time.
D) The requirement for an additional 50% capital buffer on liability claims over other classes.
An insurer is considered to have too much capital if they have no clear plan to use it for development or
growth. In such a scenario, what is a potential action the insurer might take?
B) Attract the attention of the PRA, which compromises its ability to raise more capital.
According to Principle B of the Contract Certainty Code of Practice, within how many working days must
contract documentation be provided to a consumer policyholder after entering into the contract?
A) 14 calendar days
B) 30 calendar days
C) 7 working days
D) 30 working days
For a commercial client classification, documentation must be provided within which timeframe from the
later of the inception date or the date the last insurer enters the contract?
A) 7 working days
B) 30 working days
C) 60 calendar days
D) 30 calendar days
What is the fundamental requirement for achieving contract certainty, as defined by the Code of Practice?
A) Documents must be provided promptly, within 30 days of the contract inception date.
C) The complete and final agreement of all terms between the insured and insurer must be reached by the
time they enter into the contract.
D) All terms must be clearly expressed, including any conditions or subjectivities, before the policy is issued.
The Consumer Rights Act 2015 allows a non-transparent or non-prominent contract term to be assessed for
unfairness. A term is deemed prominent if it is brought to the consumer's attention in such a way that:
A) It is expressed in plain and intelligible language (transparent).
Which statement is true regarding the Consumer Rights Act 2015 and the core terms of an insurance contract,
such as exclusions?
A) They can be challenged on the grounds of fairness if they are not brought to the consumer's attention.
D) They are defined as only the premium and the sum insured.
The standard practice of insurers to include a general exclusion in their policies concerning the Contracts
(Rights of Third Parties) Act 1999 is primarily due to which factor?
B) The Act permits the parties to contract out of its terms, and insurers are unwilling to extend liability to
non-parties.
C) It prevents the third party from ever being identified in the contract by class or description.
D) It is necessary to comply with the principle of utmost good faith ( uberrimae fidei).
Which of the following types of information is NOT classified as a 'special category' of sensitive personal
data under the legislation?
A) Health information
B) Genetic data
Which of the seven Data Protection Principles requires organisations to process no more information than
they need, stating that they must use the minimum amount of data required to fulfill their purposes?
A) Accountability
B) Purpose limitation
C) Data minimisation
D) Storage limitation
When an underwriter processes a client's personal data to carry out a risk assessment for pricing and policy terms,
which lawful basis is an insurer most likely to rely upon, provided a balancing test is passed?
A) Consent
B) Contract
C) Legitimate interests
D) Vital interests
An individual submits a Subject Access Request (SAR) to an insurer. What is the standard timeframe within which the
company should respond?
B) One month
D) Six years
To comply with the requirement for transparency under the first Data Protection Principle, what must organisations do?
A) Keep records to demonstrate compliance with the other six principles (Accountability).
B) Process personal data in ways that people would reasonably expect (Fairness).
C) Be clear, open, and honest with individuals about the personal data they are processing, and why and how they are
doing it.
D) Not process data for reasons other than those for which it was obtained (Purpose Limitation).
For the most serious data breaches, what is the maximum potential fine the Information Commissioner's
Office (ICO) may levy?
The data protection legislation governs the processing of electronic data. What is a key, but perhaps less-
known, fact about its application?
A) It does not apply to personal data that has been effectively anonymised.
D) It is mainly concerned with the processing of personal data by law enforcement authorities.
Which of the following pieces of UK legislation makes it compulsory for a business with employees to have
Employers’ Liability insurance?
Question 1
In the context of the underwriting cycle, which statement accurately describes the
simultaneous effect of a soft market on an insurer's operating costs and reinsurance
premiums?
A) The expense ratio falls because variable costs reduce, and reinsurance costs decrease in line
with lower written premium.
B) The expense ratio rises because fixed costs are applied to a diminishing premium income, while
reinsurance costs remain high due to minimum premium requirements.
C) The expense ratio remains stable due to consistent claim frequency, and reinsurance costs
increase due to higher exposure.
D) The expense ratio is mitigated by higher investment income, which offsets the increase in fixed
costs, stabilizing profitability.
Question 2
According to the principles of cycle management, what is the primary purpose for prudent
insurers to build up reserves from profit during the hard market phase?
A) To increase capacity immediately and intensify competition with newer market entrants.
B) To lower the overall expense ratio by increasing the total amount of written premium.
C) To fund anticipated losses at the bottom of the cycle, thereby ensuring the firm's survival and
solvency.
D) To return capital to investors through buy-backs before the market inevitably declines.
Question 3
Which statement accurately differentiates the primary driver of the underwriting cycle
across major insurance classes, according to past performance?
A) Both property and personal lines motor business are fundamentally price-driven due to
enhanced quotation systems.
B) Property and commercial lines are fundamentally driven by claims cost, but personal lines motor
tends to be more price-driven due to lower claims volatility.
C) Commercial lines are claims-driven, while personal lines motor and property are both driven by
investment returns.
D) All insurance lines are primarily driven by claims cost, but the effect is delayed in property
business due to long-tail liability.
Question 4
In the operation of the underwriting cycle, what is the precise sequential event that occurs
immediately after higher profits are achieved in a class of business?
B) Capacity withdrawal.
Question 5
Question 6
Under the Employers' Liability Tracing Office (ELTO) mandatory information requirements,
which of the following details must be supplied to the database within 90 days of inception?
A) Policy premium1.
C) The Employer Reference Number (ERN) including for any subsidiary companies covered3.
Question 7
How does the UK's Climate Change Act 2008 primarily address the causes of climate
change?
D) By outlining a new approach to managing and responding to climate change in the UK through
setting targets and improving carbon management8.
Question 8
Which of the following is an accurate distinction between the coverage provided by Pool Re
and Flood Re?
A) Pool Re covers commercial property for terrorism; Flood Re covers homes built after 2009 for
flood risk99.
B) Pool Re covers commercial property for terrorism; Flood Re covers homes built before 2009 for
flood risk10101010.
C) Pool Re covers private motor for terrorism; Flood Re covers commercial property for flood
risk11.
Question 9
The UK government assessed the economic cost of flooding between November 2019 and
March 2020 at approximately £333m. What critical factor is already included in this figure?
Question 10
Following the eruption of Eyjafjallajökull in 2010, which caused an unprecedented disruption to air
travel, what was the primary insurance loss incurred by travel insurers?
C) Claims by individual consumer policyholders for delay and subsequent travel abandonment.
Question 11
In response to global conflicts that affect the price and availability of oil, which resulting
scenario is known to reduce motor claims frequency and total cost?
B) Petrol shortages which are inflationary and increase operating costs, but reduce the number of
vehicles being used14.
C) Increased vehicle usage due to cheaper petrol, resulting in lower average premiums15.
Question 12
Which of the following is the defining characteristic of a home being at significant risk of
flooding in the UK, as described in the context of the Flood Re scheme?
D) The property has made a flood claim in the last five years20.
Question 13
The Swiss Re Institute's Biodiversity and Ecosystem Services (BES) Index serves which
primary function for insurers?
D) To quantify the total loss of a specific natural catastrophe event (catastrophe modelling)24.
Question 14
Which of the following is NOT one of the six commitments outlined in the insurance
industry's ClimateWise Principles?
Question 15
The High Court decision in the FCA Test Case in September 2020 and the subsequent
Supreme Court judgment in January 2021 primarily focused on providing clarity regarding
which type of insurance policy?
A) Travel insurance due to pandemic cancellation28.
Question 16
In which of the following major insurance markets is cover for natural catastrophe
(including flood) mandatory for all policyholders, who pay a premium surcharge set by the
Government?
A) UK32.
B) Germany33.
C) USA34.
D) France35.
Question 17
In the USA, how is insurance coverage typically provided for the perils of wind damage and
flood damage, respectively, under property insurance policies?
B) Wind is covered by the private market; Flood is usually covered by the private market37.
D) Wind is covered by the private market; Flood is covered by the Federal Government39.
Question 18
During a soft market phase, an insurer comes under increased pressure from
intermediaries. What is the primary reason for this pressure?
A) The pressure to maintain market share forces intermediaries to seek higher commissions to
offset their reduced income from lower premiums40.
B) The reduced capacity means intermediaries must search harder for a carrier, increasing their
operating costs41.
C) Customers demand greater discounts, forcing intermediaries to seek cheaper reinsurance.
D) Intermediaries demand a simplification of underwriting rules, conflicting with the insurer's need
for selective underwriting42.
Question 19
A) Lower reinsurance prices and increased demand for group life cover43.
B) A reduction in insurer fixed costs and the withdrawal of government guarantee schemes44.
C) Higher premiums for cover against natural disasters, and pressure on insurers' and reinsurers'
capital45.
D) Greater investment income opportunities and a mandatory switch to the CATNAT scheme46.
Question 20
What change in claims handling practice was introduced for UK subsidence claims
following the series of long hot summers after 1976?
C) The initial tendency to prescribe immediate underpinning or structural repair shifted to remedial
action followed by monitoring and repair as needed49.
D) The requirement for a policyholder to bear a portion of the risk through deductibles (excesses)
was removed50.
Q Answer Explanation
In a soft market, premium income shrinks. Fixed costs (e.g., premises) remain the
same, causing the expense ratio to rise51. Reinsurers have minimum premium
1 B
requirements, so reinsurance costs will not fall in line with the premium reduction,
maintaining pressure52525252.
At the top of the cycle (hard market), prudent insurers build up reserves from profit
2 C
to fund anticipated losses at the bottom of the cycle, thereby ensuring survival 53.
The cycle is fundamentally driven by claims cost for property and commercial
3 B lines54545454. However, personal lines, particularly private motor, tend to be more
price-driven as customers shop around due to lower claims volatility55.
The recession in the early 1990s coincided with an approximate doubling of theft
5 B claims, which led to the first of the major UK anti-fraud database initiatives, the
Claims Underwriting Exchange (CUE)57.
Mandatory information for the ELTO database includes the Employer Reference
6 C Number (ERN) including for any subsidiary companies covered 58. This
information must be provided within 90 days of inception59.
Two key aims underpin the Act: 1. Improve carbon management, thereby helping
7 D the transition towards a low carbon economy in the UK 60. 2. Demonstrate strong
UK leadership internationally61.
Although volcanic eruption is usually not a specific insured risk, the disruption led to
10 C claims by individual consumer policyholders for delay and subsequent travel
abandonment being met by travel insurers65.
Petrol shortages (e.g., due to Middle East conflicts) are inflationary but have been
11 B shown to reduce the number of vehicles being used, which in turn reduces claims
frequency and total cost66.
The FCA Test Case was initiated to provide clarity on policy terms and conditions for
15 C
Business Interruption insurance in the wake of the COVID-19 pandemic70.
In the USA, wind damage is covered through the private market, but flood is
17 D
usually excluded and covered by the Federal Government72.
Intermediaries ask for increased commission during a soft market because lower
18 A
insurance premiums have the knock-on effect of reducing their own income73.
Catastrophes of this magnitude lead to higher premiums for cover against natural
19 C disasters and pressure on insurers' and reinsurers' capital as they struggle to
meet the large losses74.