My colleague Susan Andrew has just sent me this, which I think is well worth sharing...

"The FCA has published its second consultation paper in relation to the implementation of the Insurance Distribution Directive (IDD). The original consultation, issued in March 2017, indicated that the FCA intended to issue only two consultations and it was widely anticipated that the second would not be released until September. 

It is now clear that there will be three consultations, with the FCA still planning to issue the final one in late September.  The timescale for implementation of the new rules by 23 February 2018 is extremely challenging and this second consultation give firms an earlier than expected indication of the FCA’s implementation plans.

In particular it explains that the FCA does not intend to extend rules relating to Insurance Based Investment Products (IBIPs) to pensions. This early clarity will be very welcome in the life and pensions market where many have been anticipating the potential extension of IBIPs rules to include pensions in a bid by the regulator to create greater harmonisation with investment business under MIFID II.

In addition to the FCA consultations, firms should also be drawing on EIOPA publications to inform their implementation plans. Firms cannot wait until the final FCA consultation has been concluded before starting implementation due to the lead times required for delivery of the changes."