The FCA has said that TIF must secure all books and records and preserve all information and systems relating to the following:

• The firm’s regulated activities
• All claims (including in relation to emergency medical assistance cases) and complaints handled.

TIF must retain these in a form and at a location within the UK, to be notified upon request to the FCA in writing, such that they can be provided to the FCA, or to a person named by the FCA, promptly upon its request.

Limited travel insurance and claims services provided

The latest update from the FCA states that requirements to which TIF is subject include:

1. Unless permitted by 2 (see below), TIF (itself and/or through any agent including any Appointed Representative of TIF) must not, without prior written consent of the FCA:

• Carry on any services (whether regulated activities or otherwise) for, or on behalf of, an insurer in relation to claims handling; or,
• Enter into any agreement with any insurance undertaking or insurance intermediary, whether domiciled in the UK or overseas, to provide any outsourced services relating to claims handling (including in relation to emergency medical assistance cases) and complaints handling on behalf of any such insurance undertaking or insurance intermediary.

“For the avoidance of doubt,” continued the FCA, “TIF must not carry on any insurance distribution activities in relation to any new Union Reiseversicherung AG (‘URV’) or White Horse Insurance Ireland dac (‘White Horse’) policies for any customer resident in the UK.”

Other requirements the company must follow are:

“2. For the purposes of 1, the Firm may undertake all necessary activities in relation to policies effected by the UK branch of URV prior to 8 July 2021 arranged by the firm where there are policyholders resident in the UK, including, but not limited to:

• Routine servicing matters;
• Claims handling on behalf of URV including arranging or approving emergency medical assistance, with appropriate independent oversight;
• The settlement of any sums due to third parties such as local agents, travel and accommodation providers, and medical facilities and practitioners; and,
• The handling of any complaints.”

TIF currently trades under 79 trading names in the UK market, including Citybond Suretravel, flexicover, Postcard Travel Insurance and Alpha Travel Insurance. It also offers cost containment and medical assistance services through other brands, such as Cost Containment Facilities and Emergency Assistance Facilities.