Bethan Savage
Bethan is an associate in the London insurance and reinsurance team, with experience advising clients on both non-contentious and contentious matters. On the non-contentious side, she has advised clients on insurance distribution arrangements from a regulatory perspective, and has experience drafting and negotiating distribution agreements for a range of parties, including UK banks and financial services companies. She has also supported clients through litigation and mediation proceedings.
Prior to her qualification, Bethan spent six months in Hong Kong on international secondment where she advised international clients on a variety of high-profile contentious bankruptcies and litigation cases.
Practice Area
Panel
- Contributing Author
Experience
- Hogan Lovells (2022 - Present)
Qualification
- BA, Law (2021)
Education
- Brasenose College, University of Oxford (2021)
1 Contributions by Bethan Savage
PRACTICE NOTES
UK Connected Contracts Exclusion (FSMA 2000 RAO, Article 72B): scope, qualifying providers, covered activities and FCA conduct requirements for ancillary insurance intermediaries
The general prohibition
Pursuant to section 19 of the Financial Services and Markets Act 2000 (FSMA 2000) (the general prohibition), no person may conduct a regulated activity unless authorised by the relevant regulator or otherwise exempt. Under FSMA 2000, s 23, a breach of FSMA 2000, s 19 may amount to a criminal offence. The Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO), SI 2001/544, art 66 (Chapter XVII) sets out exclusions that apply to specified categories of regulated activity. These operate to remove certain activities from the scope of Regulated Activities for the purposes of FSMA 2000, s 19. For an outline of the various general exclusions in place, see RAO, SI 2001/544. RAO, SI 2001/544, art 72B, as amended, provides a general exclusion from the perimeter of regulated activities for ‘[a]ctivities carried on by a provider of relevant goods or services’ in relation to ‘connected contract[s] of insurance’. Article 72B is often called the Connected Contracts Exclusion. Note: RAO, SI 2001/544, art 72B transposed Article 1(3) of Directive 2016/97/EU, the Insurance Distribution Directive (IDD), into English law. The UK’s implementation of the IDD came into force on 1 October 2018...
Insurance & Reinsurance
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