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Embracing the future: Why underwriters will survive and thrive with data
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Ashleigh Gwilliam
We recently spotted an article in Insurance Times in which Hubb Insure’s COO Ed Halsey predicted that underwriters will be ‘dead in the water’ in just 10 years as a result of data becoming more prominent in the insurance market. He claimed that relationships were too prevalent in the sector and that “all things are better done through data”.
With data becoming more essential in the insurance industry Halsey suggested that underwriting could soon become a thing of the past.
As the provider of Customer Lifecycle Intelligence (CLI) , powered by data analytics, artificial intelligence (AI) and machine learning (ML), you might think we’d agree. That we have some masterplan to automate underwriting to the extent that humans are no longer required. But you’d be wrong.
We align ourselves more with another commentator from this story. Phil Williams COO at Clear Group felt that underwriters would continue to exist despite the very real strides organisations are making in the use of AI and ML. He predicted instead that humans would continue to play an integral role in the underwriting process.
We too believe underwriters are better with data. So, let’s explore how data and insights are augmenting human underwriting rather than replacing it.
The digitised underwriting advantage
Underwriters with the most advanced data and analytics capabilities enjoy better operating results and performance, according to a recent report from McKinsey. The global management consulting firm claims that underwriters can see loss ratios improve three to five points, new business premiums increase 10 to 15 percent, and retention in profitable segments jump 5 to 10 percent.
Instead of being dead in the water, McKinsey believes underwriters of the future will be “portfolio managers”—empowered by artificial intelligence (AI) and digital - operating like hedge fund managers with increased leverage, scale, and insight. They believe underwriters will:
- Be able handle substantially larger books of business with more precision and control
- Use data throughout the underwriting process to inform underwriter decisions in prioritisation of prospects, validation of exposures, policy structuring, and pricing
- Rely on continuously evolving risk models that incorporate ever-expanding views of risk characteristics, tailored by line, segment, and emerging loss trends
Let’s explore how.
Increased precision and control
The process of receiving an inquiry, assessing the risk, and delivering a quote back relies on a wide array of customer and market intelligence. Data and technology can optimise the process enabling underwriters to work with increased speed, precision, and control.
Rapidly unifying data from billions of sources (both structed and unstructured) to optimise workflows, reduce risk, attract capacity, and reduce speed to quote. Whilst also allowing underwriters more time to focus on improving the customer and broker journey, winning, and retaining more customers, brokers, and markets, and operating larger books of business.
Rapid triaging of submissions
A hard market means an increase in propositions received from the broker market, but with reduced capacity. Thanks to advances in data science underwriters can, at the click of a button, screen companies against key financial metrics, flag potential risks & gaps in information and be alerted to potential moral hazards, including PEPs and Sanctions, that could prevent them placing the risk on cover.
Better decision making and precision pricing
The technical task of assessing each risk and making decisions about terms, ratings, exclusions, and pricing of a risk has always been part of the dark art of underwriting. Carefully leveraging data and technology augments this fundamental skill, allowing underwriters to making better, more intuitive decisions, faster.
Surfacing millions of structured and unstructured data points and leveraging AI and advanced analytics underwriters can build a complete 360° view of a customer risk profile and can therefore get to risk selection faster with improved decision-making, more accurate pricing, and improved loss ratios.
Proactive Risk Modelling
In a dynamic risk landscape underwriters are increasingly required to explore ways to make risk acceptable for insurance coverage, as well as keep track of emerging risk profiles. And they need to this at scale. But, in reality, without knowing the full story of a business its market and other external factors, underwriting at scale is difficult to get right – and pricing accurately and competitively is even harder.
Using a rules engine allows underwriters to automatically identify if a prospect fits its risk appetite. AI and ML can also be leveraged to learn from historical cases and classify new risk categories based on analysis of rich, contextualised data.
Continuous risk mitigation
With advanced data analytics and workflow automation customer lifecycle risk monitoring can be done proactively, not reactively. Likewise, MTAs can be addressed far more easily, and underinsurance avoided by using rules to automatically flag the changes underwriters need to know about as they occur.
Risk categories can also be reclassified and changes to the impact of specific risks can be factored into existing underwriting models to proactively mitigate risk and advise customers of corrective actions to be taken.
So, do we think underwriting will be dead in 10 years? No, we don’t.
Yes, the role of the underwriter will change. The future of underwriting will take a blended approach of human and digital.
Judgement and skill combined with advanced Customer Lifecycle Intelligence.
To find out how you can improve underwriting efficiency, enrich submissions, improve decision making, assess and monitor risk, price more accurately, improve the customer experience, reduce costs, and gain a significant competitive advantage get in touch.

Managing underinsurance with confidence
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Ashleigh Gwilliam
FullCircl asked Aviva’s Jason Chambers how brokers can tackle underinsurance with greater confidence.
According to Aviva, up to 50% of UK businesses are underinsured, with 40% only covered by a 12-month indemnity period. These shocking new statistics paint a stark picture of the huge risk the insurance sector and the businesses it serves are facing right now.
The ever-present threat of underinsurance
Underinsurance is one of the most prevalent and damaging issues impacting the insurance market in 2023. It must be tackled with confidence if we are to identify those customers most at risk, help them make informed decisions about how to tackle the crisis they are facing, and deliver better protection outcomes.
But how?
FullCircl’s Insurance Success Director Ashleigh Gwilliam held a fireside chat with Jason Chambers, Head of Underwriting Transformation at Aviva, to delve into how brokers can support customers at a time when underinsurance is an ever-present threat to their future success.
Practical underinsurance mitigation strategies
Jason shared key findings from Aviva's YouGov report, highlighting the current state of underinsurance, its own response, and invaluable insight into how brokers can use data and technology in innovative ways to:
- Proactively identify vulnerable customers
- Build a full picture of risk – material changes across an entire organisation including buildings, operations, indexation, inflation, supply chain, machinery and plant exposures
- Personalise engagement with clear, regular, and timely dialogue
- Empower customers to make informed decisions
- Deliver greater certainty around outcomes
Watch now to find how brokers can elevate their expertise, get closer to customers, and tackle underinsurance in the most confident way possible.
Want to learn more about the rising risk of underinsurance?
Check out our new report to learn more about the widening underinsurance gap facing UK Plc, and how commercial lines insurance brokers can play a critical role in helping companies get the right cover to protect them against the deepening economic storm.


Reflecting on BIBA 2023: Brokers want greater development and availability of InsurTech
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Ashleigh Gwilliam
The FullCircl team were thrilled to attend BIBA again this year. We were delighted by the sheer number of visitors to our stand, all of whom were keen to discuss the challenges they are facing - from winning more new business and retaining existing customers in a hard market, tackling underinsurance, and investing in future success whilst managing the impacts of a tough regulatory environment and the cost-of-living crisis. Likewise, the opportunity to hear from industry leading experts and make new connections is what the event is all about, and it certainly did not disappoint.
The standout headline for us was that attendees voted for greater development and availability of InsurTech to help with efficiency, evolving customer needs, and cost reduction in a poll during a session entitled ‘What’s Coming Up for Brokers’. This gained 25% of the vote, coming a close second to their top wish list item - a period of stability with no regulatory or legislative changes.
FullCircl is well positioned to assist brokers with both - but we’ll come back to that later.
A record-breaking success
It was fantastic to see the insurance community come together to ‘Rise to the Challenge’, as insurers, brokers, intermediaries, specialists, and service providers joined forces to debate the problems and solutions facing the industry as it looks to the future.
An exciting two days of networking, expert insights and challenging debate, this year’s event brought in record footfall with over 9,000 attendees. Summing up the event, Ashleigh Gwilliam, FullCircl’s Insurance Success Director commented:
“If you work in insurance, you must be at BIBA! Where else can you catch up with so many of your existing clients, prospects, and partners in two days. This year’s theme, Rise to the Challenge, is really defined by pan-industry collaboration, and a true sense that we are all in it together to deliver better results for customers. We are still feeling the effects of the pandemic, inflation, and the hard-market – with underinsurance still prevalent, it was great to have so many conversations about how brokers and underwriters can utilise data and insight to take proactive steps to protect and support their clients.”
Our key BIBA 2023 takeaways
So, what did we learn? Here are our top 3 key takeaways from the event.
- Data will be vital in helping brokers deal with the vagueness of principles-based regulation. With the Consumer Duty set to raise standards and clarity around consumer protection (and consumer means all retail customers, including SMEs), data will play a key role in reducing the complexity, time and cost associated with fair value assessments. It will also be vital in terms of building a deeper understanding of the customer – what they need, why they need it – and helping measure, record, review, and improve across the entire customer lifecycle. As a fellow industry commentator recently pointed out “by streamlining the data acquisition process for brokers so that a 360-degree picture of an individual’s insurance background can be built instantly, customers can enjoy a smooth onboarding process, a better customer journey and overall experience”. We couldn’t agree more.
- The relationship between insurers and brokers is more vital than ever – data can facilitate greater collaboration. It’s about harnessing technology to build an ecosystem of data-driven collaboration that will reduce complexity, boost efficiency and drive innovation. The more data, the more ideas, and the more opportunity to close the protection gap, tackle underinsurance, respond to emerging complex risks and exposures, and improve the customer experience. Leaders agreed that innovation and the implementation of technology is vital to the survival of the insurance sector and broker business. We agree! Greater access to Customer Lifecycle Intelligence allows brokers to make the best possible submissions to underwriters and armed with this better-quality intelligence underwriters can make more accurate assessments of risk and therefore provide better terms and prices to the broker’s clients. Better business, faster – brokers can rely on their underwriter relationships to insure their clients, and underwriters can rely on their broker relationships to present new opportunities for profitable growth in a hard market. Neither can thrive without the other, they must collaborate and innovate in unison.
- The future of insurance service is going to be about finding the sweet spot between humans and technology. There is an urgent requirement to deliver greater customer experiences to improve the value proposition of the sector. Success drivers for brokers include customer focus, speed of response, knowledge, communication, and delivery, and all must be underpinned by strategic data-driven decision making. The challenge of course, is how to build the perfect hybrid solution. We believe a great personal experience has technology at its heart – that is the Customer Lifecycle Intelligence difference.
How is FullCircl helping the insurance sector ‘Rise to the Challenge’?
FullCircl is already helping 85+ insurance businesses, including 8 of the top 10 brokers to:
- Prospect with precision: Brokers can harness data on over 5 million companies in the UK and use powerful filters to narrow these down to a workable prospect list. In addition, the connected structured and unstructured insights provide new opportunities for brokers to engage and establish credibility through well-timed, highly relevant and differentiated outreach.
- Prepare better underwriting submissions: Brokers can leverage data-driven customer intelligence that ensures no knowledge gaps, and that the submission process is both aligned with customer needs and the requirements of tougher risk-averse underwriting conditions.
- Increase client retention: Brokers receive daily insights into changes in their client’s world, flagging potential issues and reasons to engage throughout the period of cover – e.g. changes in management; potential mergers and acquisitions; change of premises; relationship triggers; potential financial risks and market opportunities.
- Cultivate existing book of business: Daily insights into the client’s world offer brokers the perfect way to trigger conversations about additional product lines. Upselling and cross-selling mean not only are policies per account more profitable, but a stronger sense of trust is fostered, establishing the broker as an advisor rather than simply a service provider.
We want to help you too.
FullCircl empowers your team with rich, contextualised company information on every business in the UK and Ireland. Information you can use for commercial insurance risk management purposes and to carry out deeper risk-based monitoring. With complete clarity on your market provided by sector specialism and vertical integration, you’ll always have the information - and the CLI tools - you need.
Get in touch with a member of our team today, to find out how we can work in partnership to ensure you ‘Rise to the Challenge’.


What Does The Future of the Insurance Industry Look Like?
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Ashleigh Gwilliam
For years, decades even, there’s been a predominant way that small insurance brokers become larger entities and that is by merging and acquiring. Two smaller brokers merge, acquire a third, and suddenly, in a few short months, they’re a much larger broker.
But is that model really sustainable in 2023 and beyond? Let’s explore the general market and some of the issues insurers are facing.
The entire insurance industry has seen no end of challenges and issues in recent years, and brokers are operating in a hard market. As you know, a hard market is where there is higher demand for insurance but a decreased appetite to provide that insurance, due to increased risk. On a national scale, issues including Brexit, pressures on the NHS, and skyrocketing inflation have all seen claims costs rise dramatically. The Royal Gazette reported on March 7th 2023 at the Bermuda Risk Summit that this is the hardest market the industry has seen for 50 years.
Globally, geopolitical tensions surrounding Russia and Ukraine, China and the USA are also causing prices to rise. And of course years of Covid-19 lockdowns continue to impact on the economy as a whole.
These are just issues that are already biting. In 2023, the entire insurance industry can expect to see regulatory challenges, further changes to working methods and changing customer behaviours, especially when it comes to digital products.
With all this to contend with, mergers and acquisitions can no longer be the key driver of growth for the insurance industry. Growth will need to be organic, and it’ll need to be steady but what does the future hold in this area?
What does the future hold for the insurance industry?
Throughout 2021 and 2022, even with the dual challenges of Covid-19 and Brexit, the industry saw a heavy focus on mergers and acquisitions to acquire larger market share; however, in these earliest months of 2023, we’re seeing signs that times are changing.
Mergers and acquisitions have slowed, with organic growth seen as the low risk way to ensure success while meeting the year’s big challenges head on. In the US, mergers were down 8% in 2022 when compared to the figures for 2021 and, globally, things are set to be even more unpredictable in 2023.
Here are some of the challenges facing insurers in 2023:
- Underinsurance: The first of these challenges is underinsurance. Spiralling materials and labour costs brought on by double-digit inflation, combined with a lack of consumer education on this issue, means that many customers may be unable to fund rebuilding costs with their existing policies.
- Mergers & Acquisitions being less financially viable: The business valuation multipliers when calculating the value of a brokerage for sale have increased, due to the amount of M&A activity that has been happening in the sector. This means that it’s less commercially viable to acquire a new brokerage in the current financial climate.
- High Customer Demands: Demand for the benefits provided by newer forms of InsurTech is a market disruption that can’t be solved by a merger unless a broker can find a partner who’s already invested in cutting-edge technology.
The only way to meet these challenges is with organic growth in the following ways:
- Growth that is built around improving customer relationships and guiding them towards full coverage.
- Growth that is built around understanding new customers and the risk exposure involved in covering them.
- Growth built around the right data analysis tools and technology.
How can you stand strong against future changes in the insurance industry?
The best way to protect your brokerage from future challenges is by being big enough to tackle them. Growth is a great protection, as it minimises the amount of risk to which an individual customer will expose you, while giving you a solid enough footing to overcome any temporary setbacks.
Organic growth doesn’t happen automatically. There are three things you need to consider to help you stand strong against future challenges as your business grows:
- Know Your Business (KYB): KYB is crucial for safe growth. Firstly, you’re protected from risk as you’re aware of the individual circumstances of any client you bring on board. Secondly, a higher understanding means better service, happier clients, more recommendations and, ultimately, faster growth.
- Customer Lifecycle Intelligence (CLI): CLI tools build upon what you’ve learned from your KYC efforts. As you work alongside a customer, you’re able to predict what the future holds for them, so you can make informed decisions to prevent underinsurance and lower risks even further - all while improving customer service.
- Data Awareness: Having the data from innovative InsurTech tools is one thing. Having a culture of data awareness is what will help your brokerage avoid or overcome challenges and set yourself up for organic growth in 2023 and beyond.
How becoming more data aware can benefit your brokerage
By being aware of customer data, you’ll be able to support your proactive outlook and constantly advise and protect your clients. With your grasp of data forewarning them about potential underinsurance risks, they’ll trust your services more than ever.
You’ll have increased awareness of key personnel changes at each of your customers - so it’ll be easy to maintain solid personal relationships even as your customers hire and fire. You’ll also be aware if a key member leaves and isn’t replaced - something that’s often a red flag situation.
Personnel changes won’t be the only red flag to look out for. Analysing the data will help you spot financial trouble or credit issues, meaning you can act quickly to either offer a client advice and support, or to plan for life without them - safely future-proofing your brokerage and ensuring growth isn’t hindered.
All of this combined will help enhance your reputation. By understanding your customers and building solid relationships, you’ll build a reputation as the kind of brokerage that puts customer needs first. A brokerage that can see - and solve - problems before they arise.
How can FullCircl help your business grow organically?
FullCircl provides unparalleled support and training to complement our Customer Lifecycle Intelligence platform.
Our tools empower brokers to enrich conversations with clients about their changing cover needs and any issues impeding growth, offering a cohesive method of doing this across your broker teams that helps prevent complaints, legal actions and FCA fines while aiding growth into 2023.
For more information and to start becoming more data aware, email letstalk@fullcircl.com


How to protect your clients from underinsurance
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Ashleigh Gwilliam
Underinsurance is one of the most significant issues facing the insurance industry in 2023. As a potential risk to your clients and your brokerage’s reputation, It’s something that should be easily identified by risk-based monitoring and commercial insurance risk management audits; however, as widespread as underinsurance is, it can still go overlooked due to a number of factors.
And with clients becoming ever more savvy when it comes to reviewing and approaching brokers, it’s more important than ever to reduce or eliminate the risk of underinsurance.
But how does your brokerage identify and tackle underinsurance? How do you find out which of your clients are underinsured so that you can take steps to fix it? Let’s take a look at just how you can - and should - review your insurance portfolio to protect yourself, and your customers.
Why is underinsurance suddenly such a problem?
Underinsurance has always been an issue for brokers because of the issues it can cause for your customers. But now, more and more external factors are compounding the issue. Firstly, there’s the general economic situation. With double-digit inflation, the sum insured payable when claiming on a policy simply doesn’t stretch as far as it once did.
Add on the rising costs of rebuild materials, businesses cutting back on premiums in an attempt to conserve much needed funds, and the perennial issue of customers not giving insurers accurate information at the underwriting stage and it’s easy to see why accurate underwriting and risk analysis is a bigger problem than ever before.
The effects of underinsurance are clear to see and have a far-reaching impact. Imagine one of your customers suffering fire or flood damage to their place of business and thinking they’re fully covered; however, what they didn’t do is inform you about the valuable new equipment they’d invested in. This may now mean that their sum insured isn’t enough to cover the higher cost to get them back up and running.
That’s going to damage your relationship with the client, and potentially your reputation. But that’s not all.
As well as your customer being unhappy with your informing them they are underinsured at a time of great stress and upheaval, they run the real risk of going out of business if their rebuild costs are too high and their policy only covers a portion of this outlay. You’ll lose the client, and with reputation damage compounding the issue, you’ll find it hard to find new customers to replace them.
The good thing to take away is that there is a way to minimise the risk of this happening. It’s time to take commercial insurance risk management seriously and look at ways to reduce the threat of underinsurance.
In the next three steps, we’ll show you how.
Step One: Regularly review your portfolio and the general market
As we’ve discussed, the risks of underinsurance to both your customers and your brokerage are very real, and can have lasting, damaging effects. If you wait until a customer makes a claim to realise that they aren’t insured for the correct amount, it’s far too late.
On the flip side, if you can ensure clients are always fully covered, and provide them with the right advice before any claims are made, a great proportion of this risk will be eliminated entirely. Lower risks mean happier, better protected clients, who in turn are more likely to work with and recommend your brokerage.
To do this, the first thing to do is review your mindset. Instead of offering reactive advice - “this has happened, here’s what to do,” you should offer more proactive advice - “this is what may happen, here’s how to prevent it.” As a respected broker, you’re probably already doing that but you can never have too much information about the industry and your customers during a hard market.
Fully proactive advice means spotting potential issues before they affect the client and that’s where better risk-based monitoring comes in. Constant review of the market and how this relates to your clients is the order of the day. By understanding your customers and impending changes in the market using CLI tools and other methods, you’ll be well aware of what’s ahead.
Once you’ve settled on a proactive commercial insurance risk management approach, you need to know how to deliver it. And that means improving your analytical processes.
Step Two: Analyse your portfolio for signs of underinsurance
There are a wide range of analytical tools and techniques you can use - many of them available from FullCircl - but before you invest in a single tool, there’s an incredibly simple way you can start your analysis.
Pick up the phone and ask.
Regularly speaking to your clients about their cover, and new investments into their business, means you’ll be well placed to advise them if they’re underinsured. It’s all about understanding your customers, their needs, and their insurance requirements so that you can mitigate risk on their behalf.
That’s not all you’ll need to understand.
You need to be well versed in the insurance industry as a whole and have an in-depth understanding of the current moving parts in each sector of the industry, so that you can identify potential issues and move quickly to safeguard your clients. The best way to do that is by ensuring you’re always up to date with what’s happening in their world by conducting regular data analysis and setting up alerts.
Once you’re fully informed about your customers' situations and the industry as a whole, you can focus on carrying out an in-depth analysis of your portfolio.
This is where Customer Lifecycle Intelligence (CLI) tools come in useful. These tools make it easy to analyse the current value of cover for a specific customer against the future value of their assets, for example. If the former won’t cover the latter, you’ll be made aware ahead of time so that you can bring it up with your clients. They’ll be able to adjust their cover to protect their business - and your brokerage - from the consequences of underinsurance.
The more data you can gather from your proactive outlook and analytical tools, the more aware you’ll be.
This leads us nicely onto step three, which details the benefits of getting ahead of your industry and key changes by becoming much more data aware.
Step Three: Become more data aware
Having the right mindset and the right tools are one thing. Committing to using them properly and becoming more data aware is what will really benefit your brokerage.
By being aware of - and increasingly familiar with - customer data, you’ll support your proactive outlook and know exactly how to constantly advise and protect your clients. With your grasp of data forewarning them about potential underinsurance risks, they’ll trust your advice more than ever.
Also, by being aware of industry data, you’ll have a deeper understanding of the risks and opportunities within your entire portfolio, prompting you to start the important conversations that lead to even deeper trust and much more organic growth.
All that combines to enhance your reputation as the kind of insurance broker who puts customer needs first. The kind who can see - and solve - problems before they arise.
That’s the kind of broker any client would like to work with.
How can FullCircl help you protect your clients against underinsurance?
FullCircl empowers your team with rich, contextualised company information on every business in the UK and Ireland. Information you can use for commercial insurance risk management purposes and to carry out deeper risk-based monitoring. With complete clarity on your market provided by sector specialism and vertical integration, you’ll always have the information - and the CLI tools - you need.
For more information and to start becoming more data aware, email letstalk@fullcircl.com.


Regulation Update: Progress of the Economic Crime and Corporate Transparency Bill
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Justin Fitzpatrick
Here’s what we’re excited about…
Following its progress through the House of Commons, the Economic Crime and Corporate Transparency Bill (ECCTB) is now at committee stage in the House of Lords. The expectation is that the new legislation will receive royal assent by the summer.
Quick Recap - What is the Economic Crime and Corporate Transparency Bill?
As mentioned in our previous update, the ECCTB follows on from the Economic Crime (Transparency and Enforcement) Act, which was passed in March 2022 in response to the Russia/Ukraine conflict and served to significantly simplify the process for imposing sanctions, identifying, and tracing illicit wealth, and preventing ‘oligarchs’ from seeking damages.
The new ECCTB legislation aims to further strengthen the UK’s approach to tackling economic crime, including fraud, money laundering, corruption, and other forms of organised crime. The Bill also seeks to increase the transparency and accountability of the corporate sector, by strengthening the powers of Companies House and increasing the amount and availability of information companies provide to ensure they operate in a responsible and ethical manner. In this regard there are four key objectives:
- Ensure those required to deliver documents to Companies House do so, and that the requirements relating to proper delivery are complied with.
- Ensure documents delivered to Companies House contain all the information they are required to, and that the information provided is accurate.
- Minimise the risk of information on the register creating a false or misleading impression to members of the public.
- Minimise the extent to which companies and other firms carry out unlawful activities or facilitate the carrying out of unlawful activities by others.
Current progress of the Economic Crime and Corporate Transparency Bill
In the most recent session, held on 27th March, the committee approved amendments to the Sanctions and Money Laundering Act 2018 which would enable new regulations under the new ECCTB for imposing director disqualification sanctions on designated persons. This will also be complemented by approved amendments to the Directors Disqualification Act 1986, making it an offence under ECCTB for a person subject to sanctions to act as a company director.
In addition, the committee adopted amendments regarding the provision of requisite information to be provided by subscribers of registration of a company, and the delivery of documents to the registrar of companies - Companies House.
As the ECCTB progresses towards royal assent, here are three key things we are excited about:
Filing Exemptions:
The ECCTB makes provision for several Companies House filing exemptions to be removed. This means:
- Companies with shares admitted to trading on a regulated market will now be required to file a confirmation statement.
- Dormant companies with no significant accounting transactions will now be required to file accounts.
- Small companies will be required to file a profit and loss account and a director’s report.
- Certain community interest companies will now be required to file accounts and annual returns.
This is great news. With this additional information, small and medium sized businesses (SMBs) can be risk screened a lot earlier by banks and financial service providers, allowing for more accurate decision making about which companies they wish to enter into relationships with, as well as the opportunity to onboard them faster and monitor their activities for better product and service matching and improved in-life customer experiences.
Director identity verification:
The ECCBT sets out that all new and existing directors of UK corporates will be required to verify their identity, and that this obligation extends to all current directors irrespective of the date they were appointed. Annual confirmation statements will be required to include evidence of each director’s identity having been accurately identified and verified. UK companies will also be required to ensure that no person acts as a director unless their identity has been verified and filed.
Director identity verification will make it much harder to register fictitious directors or beneficial owners, thereby reducing the ability for people to use Companies House to legitimise nefarious business activities. Banks and financial service providers will benefit from greater assurance that the people behind the companies are who they say they are, thereby helping them meet regulatory requirements when entering into new, and maintaining existing, customer relationships.
Shareholder Information:
The ECCTB makes provision for new requirements on shareholder information including:
- Companies will be required to maintain a record of all individuals and entities with significant control over the company, and to file this information with Companies House.
- The definition of “significant control” will be expanded to include not only those who hold more than 25% of company shares or voting rights, but also those who exercise influence or control over the company in other ways.
- Companies will be required to update this information on a regular basis, and to notify Companies House of any changes to share ownership or voting rights information.
- Companies will also be required to provide information on their Ultimate Beneficial owners, including names, date of birth and address information.
Again, this is great news. The current Persons of Significant Control Register is a little sloppy, requiring banks and financial service providers to rely upon probabilistic matching to identify shareholders, persons with voting rights, or those with influence over a company. This is made even more difficult thanks to increasingly complex corporate structures and fragmented ownership data, making it harder to assess risk and meet regulatory requirements.
Helpful tip: FullCircl recently launched a new product that helps connect the dots on corporate ownership by providing a complete view including Summary of Ownership, Persons of Significant Control, shareholder data, corporate family tree, subsidiary data, portfolio companies and Ultimate Beneficial Ownership (UBO) data. In addition, our UBO API endpoint is able to identify and throw back anomalies in ownership data.
What does this mean for banks and financial service providers today?
The transformation of Companies House from a passive library to a proactive gate keeper will not happen overnight. Realistically, it’s going to take considerable time for Companies House to manoeuvre through this, and we can likely expect a phased approach to both implementation and remediation.
Forewarned is forearmed, however. Staying ahead of ECCBT reform requires investment now. As the legislation progresses towards royal assent and reforms are rolled out, those able to achieve a greater focus on transparency and data quality will be ahead of the field and in position to take greatest advantage of the improvements the Bill delivers.
What does this mean for FullCircl customers?
We are excited about the ECCBT and the impact it will have in terms of greater transparency, accuracy, and reliability of data. After all, the more reliable the data, the more valuable our tools, applications and business logic become – helping our customers find customers that fit their risk profile, onboard them quicker and keep them for life.
Customer Lifecycle Intelligence is not static data - we deliver a multi-dimensional view that combines advanced data ingestion, validation, data matching, and augmentation with real-time media screening and more. All neatly delivered via web app or API.
Whether it’s automated data collection and critical checks, ensuring compliance, confidently targeting the right customers, or growing advocacy through frictionless onboarding and support, FullCircl is helping the UK’s leading banks and financial services providers do Better Business, Faster.
Get ahead of ECCBT reform
If you have questions about the potential impact of the Economic Crime and Corporate Transparency Bill and how to prepare for it, or indeed if you have regulatory or compliance concerns that impact how you acquire, onboard, and serve customers - we would love to talk to you. Just email us at letstalk@fullcircl.com.