🧭 Ethics & competency; dispute resolution

1. Under the Central Bank's Fitness and Probity Standards, a person performing a controlled function in a regulated firm must, among other requirements, act honestly, ethically and with integrity. Which additional requirement must also be satisfied under those Standards?

1. Be competent and capable, and be financially sound
2. Hold a university degree in a business-related discipline
3. Have at least ten years' industry experience
4. Be a shareholder of the regulated firm

The Fitness and Probity Standards require a controlled function holder to be competent and capable, to act honestly, ethically and with integrity, and to be financially sound; there is no set degree, minimum experience or shareholding requirement. (Central Bank Reform Act 2010, Part 3; Fitness and Probity Standards (Central Bank of Ireland))

2. An individual is due to be appointed to a pre-approval controlled function (PCF) within an insurance intermediary firm. Before the individual can take up the role, what must happen?

1. The Central Bank must grant its prior approval of the appointment
2. The firm must merely notify the Central Bank within one month of appointment
3. The individual must complete 15 hours of CPD before appointment
4. The individual's professional body must certify their fitness for the role

PCF roles require prior Central Bank approval before the individual takes up the position, which distinguishes them from controlled functions generally that only require ongoing compliance with the Fitness and Probity Standards; approval is not delegated to the firm or a professional body. (Central Bank Reform Act 2010, Part 3; Fitness and Probity Standards (Central Bank of Ireland))

3. Which of the following reflects one of the Standards for Business under the Consumer Protection Code 2025 governing a regulated entity's dealings with customers?

1. Act honestly, fairly and professionally in the best interests of its customers
2. Maximise commission income from each product sale
3. Prioritise the regulated entity's market share over customer outcomes
4. Recommend only the regulated entity's own in-house products

The Consumer Protection Code 2025 Standards for Business require a regulated entity to act honestly, fairly and professionally in the best interests of its customers and the integrity of the market, not to prioritise sales or its own products. (Consumer Protection Code 2025, Standards for Business (Standards for Business Regulations 2025))

4. The Consumer Protection Code 2025 Standards for Business require a regulated entity to act with a particular standard of competence when providing a service to a customer. How is that standard expressed in the Code?

1. With due skill, care and diligence
2. With maximum speed regardless of accuracy
3. With the minimum effort compliant with the letter of the law
4. With discretion left entirely to sales targets

The Consumer Protection Code 2025 Standards for Business require a regulated entity to act with due skill, care and diligence in the best interests of its customers; this is the Code's expression of the competence principle. (Consumer Protection Code 2025, Standards for Business (Standards for Business Regulations 2025))

5. An APA holder is advising a customer on a home insurance policy and knows that a competitor's product would suit the customer's needs better than any product the adviser's own firm offers. Consistent with the Consumer Protection Code 2025 Standards for Business, the adviser should:

1. Ensure the customer is not misled about the suitability of the firm's own product
2. Recommend the firm's product regardless, since disclosure duties do not extend to competitors
3. Withhold information about the product's limitations to secure the sale
4. Advise the customer only after the sale has been completed

The Consumer Protection Code 2025 Standards for Business prohibit misleading a customer, so the adviser must not overstate the suitability of the firm's product; concealing limitations or delaying advice would breach the 'not mislead' and 'best interests' principles. (Consumer Protection Code 2025, Standards for Business (Standards for Business Regulations 2025))

6. Which ethical principle requires an insurance adviser to ensure that personal interests, incentives or relationships do not improperly influence the professional advice given to a customer?

1. Objectivity
2. Confidentiality
3. Professional behaviour
4. Financial soundness

Objectivity requires advice to be free from bias, conflicts of interest or undue influence, which is distinct from confidentiality (protecting client information) or professional behaviour (complying with standards and avoiding conduct that discredits the profession). (Consumer Protection Code 2025, Standards for Business and conflicts of interest requirements (Central Bank of Ireland))

7. During a client meeting, an APA holder learns confidential medical information relevant to a life assurance application. A family member of the client later asks the adviser to share this information informally. Consistent with the confidentiality principle, the adviser should:

1. Decline to disclose the information unless the client consents or disclosure is required by law
2. Share the information, since family members are treated as part of the customer relationship
3. Disclose only the parts of the information that seem harmless
4. Provide the information verbally to avoid creating a written record

Confidentiality requires client information to be protected and disclosed only with consent or where legally required; informal disclosure to a third party, even a family member, breaches this principle regardless of format or partial content. (Consumer Protection Code 2025 Standards for Business (protection of consumer information); Data Protection Act 2018)

8. A branch manager asks an APA holder to backdate a customer's application form so that a compliance breach relating to a missed disclosure deadline is not apparent on file. If the adviser complies, which ethical principle is most directly breached?

1. Integrity
2. Objectivity
3. Confidentiality
4. Competence

Backdating a document to conceal a breach is a dishonest act, which most directly breaches integrity (acting honestly and avoiding deception), rather than objectivity, confidentiality or competence, which concern different aspects of professional conduct. (Fitness and Probity Standards - requirement to act honestly, ethically and with integrity (Central Bank of Ireland))

9. The Minimum Competency Code 2017 was given legal force by regulations made under which statutory provision?

1. Section 48(1) of the Central Bank (Supervision and Enforcement) Act 2013
2. Section 33AN of the Central Bank Act 1942
3. Section 10 of the Consumer Protection Act 2007
4. Article 10(2) of Directive (EU) 2016/97

The Minimum Competency Regulations 2017 (S.I. No. 391 of 2017), which give the MCC 2017 legal force, were made under section 48(1) of the Central Bank (Supervision and Enforcement) Act 2013; the other provisions relate to different regimes. (Central Bank (Supervision and Enforcement) Act 2013, section 48(1); Minimum Competency Regulations 2017 (S.I. No. 391 of 2017))

10. On what date did the Minimum Competency Code 2017 and the accompanying Minimum Competency Regulations 2017 take effect?

1. 3 January 2018
2. 1 January 2018
3. 3 January 2017
4. 1 January 2019

The Minimum Competency Regulations 2017 (S.I. No. 391 of 2017) and the MCC 2017 took effect on 3 January 2018, a date distinct from the Financial Services and Pensions Ombudsman's separate commencement date of 1 January 2018. (Minimum Competency Regulations 2017 (S.I. No. 391 of 2017); Minimum Competency Code 2017 (Central Bank of Ireland))

11. Both the CPD requirement under the Minimum Competency Code 2017 and the annual professional training/development requirement under Article 10(2) of the Insurance Distribution Directive, as transposed into Irish law, set the same minimum number of hours per year. What is that number?

1. 15 hours
2. 10 hours
3. 20 hours
4. 12 hours

The MCC 2017 requires 15 hours of formal CPD per CPD year, and Article 10(2) IDD, as transposed by S.I. No. 229 of 2018, separately requires at least 15 hours of professional training or development per year. (Minimum Competency Code 2017, CPD chapter; Directive (EU) 2016/97, Article 10(2); European Union (Insurance Distribution) Regulations 2018 (S.I. No. 229 of 2018))

12. A newly recruited adviser has not yet obtained the recognised qualification required for a retail insurance advice role. Under the Minimum Competency Code 2017 new entrant provisions, on what basis and for how long may this person perform the retail function before the qualification is obtained?

1. On a supervised basis, for a maximum of 4 years
2. Unsupervised, for a maximum of 4 years
3. On a supervised basis, for a maximum of 2 years
4. Unsupervised, provided CPD hours are completed

The MCC 2017 allows a new entrant to perform a retail function only on a supervised basis, within a maximum period of 4 years to obtain the recognised qualification. (Minimum Competency Code 2017, provisions on New Entrants (Central Bank of Ireland))

13. For the purposes of the Consumer Protection Code 2025, which of the following is included within the definition of 'consumer' entitled to protection under the Code's complaints-handling provisions?

1. An incorporated body whose annual turnover in the previous financial year does not exceed €3 million
2. An incorporated body whose annual turnover in the previous financial year does not exceed €5 million
3. Any incorporated body, regardless of turnover
4. Only natural persons acting in a personal capacity

The Consumer Protection Code 2025 defines 'consumer' to include natural persons and incorporated bodies with annual turnover not exceeding €3 million, subject to the group turnover exclusion; it is not limited to natural persons nor open to all companies. (Consumer Protection Code 2025, definition of 'consumer' (Central Bank of Ireland))

14. A small limited company had an annual turnover of €2.4 million in its previous financial year but is a member of a corporate group whose combined turnover is €6 million. For the purposes of the Consumer Protection Code 2025 'consumer' definition, this company is:

1. Excluded, because it is a member of a group whose combined turnover exceeds the threshold
2. Included, because its own individual turnover is below €3 million
3. Included, because group turnover is irrelevant to the definition
4. Excluded, because only sole traders qualify as consumers

The Consumer Protection Code 2025 definition excludes an incorporated body that is a member of a group with combined turnover above the €3 million threshold, even where the entity's own individual turnover falls below that threshold. (Consumer Protection Code 2025, definition of 'consumer' - group turnover exclusion (Central Bank of Ireland))

15. Under the Consumer Protection Code 2025 complaints-handling procedure, within how many business days of receiving a complaint must a regulated entity issue a written acknowledgement to the complainant?

1. 5 business days
2. 10 business days
3. 20 business days
4. 40 business days

The Consumer Protection Code 2025 requires acknowledgement of a complaint within 5 business days of receipt; 20 and 40 business days relate to later stages of the process, namely updates and overall resolution. (Consumer Protection Code 2025 (Consumer Protection Regulations 2025), complaints resolution requirements)

16. A regulated entity receives a written complaint on Monday, 2 March 2026, a business day, with no public holidays falling before the acknowledgement is due. If the entity acknowledges the complaint on the fifth business day (counting the day of receipt itself as the first business day) as permitted by the Consumer Protection Code 2025, on what date is the acknowledgement issued?

1. Friday, 6 March 2026
2. Monday, 9 March 2026
3. Thursday, 5 March 2026
4. Friday, 13 March 2026

Counting 2, 3, 4, 5 and 6 March 2026 as business days 1 to 5 (Monday to Friday, with no weekend falling within this run), the fifth business day falls on Friday 6 March 2026; the other options result from miscounting a day or adding an extra week. (Consumer Protection Code 2025 (Consumer Protection Regulations 2025), complaints resolution requirements)

17. Under the Consumer Protection Code 2025, while a complaint is being investigated, a regulated entity must provide the complainant with a regular written update at intervals not exceeding how many business days?

1. 20 business days
2. 5 business days
3. 40 business days
4. 10 business days

The Consumer Protection Code 2025 requires written updates at intervals not exceeding 20 business days; 5 business days is the acknowledgement deadline and 40 business days is the overall resolution timeframe under separate provisions. (Consumer Protection Code 2025 (Consumer Protection Regulations 2025), complaints resolution requirements)

18. A firm issued its first written update to a complainant on business day 1 of its investigation and did not issue its next update until business day 25. Has the firm met the update requirement of the Consumer Protection Code 2025?

1. No, because updates must be issued at intervals not exceeding 20 business days
2. Yes, because there is no fixed maximum interval between updates
3. No, because updates must be issued at intervals not exceeding 10 business days
4. Yes, because the 40-business-day resolution period had not yet elapsed

The Consumer Protection Code 2025 caps the interval between updates at 20 business days, so waiting until business day 25 breaches the requirement regardless of the overall 40-business-day resolution timeframe. (Consumer Protection Code 2025 (Consumer Protection Regulations 2025), complaints resolution requirements)

19. Under the Consumer Protection Code 2025, within how many business days must a regulated entity attempt to investigate and resolve a complaint?

1. 40 business days
2. 20 business days
3. 30 business days
4. 60 business days

The Consumer Protection Code 2025 sets a 40-business-day timeframe for attempting to investigate and resolve a complaint; 20 business days is the update interval, while 30 and 60 business days are not the figures used in the Code. (Consumer Protection Code 2025 (Consumer Protection Regulations 2025), complaints resolution requirements)

20. A regulated entity has not resolved a customer's complaint after 40 business days have elapsed since receipt. Consistent with the Consumer Protection Code 2025, the firm must:

1. Inform the consumer of the anticipated timeframe for resolution and of the right to refer the complaint to the Financial Services and Pensions Ombudsman
2. Close the complaint file and take no further action
3. Automatically pay compensation to the consumer without further investigation
4. Refer the matter directly to the courts on the consumer's behalf

The Consumer Protection Code 2025 requires the firm, once the 40-business-day period elapses without resolution, to inform the consumer of the anticipated timeframe and of the right to refer the complaint to the FSPO; it does not require automatic compensation, closure, or court referral. (Consumer Protection Code 2025 (Consumer Protection Regulations 2025), complaints resolution requirements)

21. For the purposes of calculating the business-day timeframes in the Consumer Protection Code 2025 complaints-handling procedure, which of the following is generally excluded from the count?

1. Saturdays, Sundays and public holidays
2. Only Sundays
3. Only public holidays, but not weekends
4. Weekday afternoons after 5pm

'Business days' for the purposes of the Consumer Protection Code 2025 complaints-handling timeframes exclude Saturdays, Sundays and public holidays, not merely Sundays or public holidays alone. (Consumer Protection Code 2025 (Consumer Protection Regulations 2025), complaints resolution requirements)

22. Which of the following is NOT one of the complaints-handling timeframes set out in the Consumer Protection Code 2025?

1. Providing a final response within 60 business days of receipt
2. Acknowledging a complaint within 5 business days of receipt
3. Providing updates at intervals not exceeding 20 business days
4. Attempting to investigate and resolve a complaint within 40 business days

The Consumer Protection Code 2025 sets timeframes of 5, 20 and 40 business days for acknowledgement, updates and resolution respectively; there is no separate 60-business-day 'final response' timeframe in the Code. (Consumer Protection Code 2025 (Consumer Protection Regulations 2025), complaints resolution requirements)

23. Under Irish law, the Minimum Competency Code 2017 is given legal force by regulations made under which statutory provision?

1. Part 3 of the Central Bank Reform Act 2010
2. The Consumer Protection Act 2007
3. Section 48(1) of the Central Bank (Supervision and Enforcement) Act 2013
4. The provisions of the Consumer Protection Code 2025

The Minimum Competency Regulations 2017 (S.I. No. 391 of 2017), which give the Code legal effect, were made under section 48(1) of the Central Bank (Supervision and Enforcement) Act 2013; Part 3 of the 2010 Act instead underpins the separate Fitness and Probity regime. (Central Bank (Supervision and Enforcement) Act 2013, s.48(1); Minimum Competency Regulations 2017 (S.I. No. 391 of 2017))

24. The Minimum Competency Regulations 2017 and the Minimum Competency Code 2017 took effect on which date?

1. 1 January 2018
2. 3 January 2018
3. 1 January 2019
4. 3 January 2019

The MCC 2017 and Regulations 2017 took effect on 3 January 2018; 1 January 2018 is instead the commencement date of the Financial Services and Pensions Ombudsman under the FSPO Act 2017, a frequently confused near date. (Minimum Competency Regulations 2017 (S.I. No. 391 of 2017), Central Bank of Ireland)

25. How does the scope of the Minimum Competency Code 2017 differ from that of the Central Bank's Fitness and Probity Standards?

1. The Fitness and Probity Standards replaced the Minimum Competency Code when both regimes took effect in January 2018
2. The Minimum Competency Code applies only to credit institutions, while Fitness and Probity applies only to insurance undertakings
3. Both regimes apply exclusively to persons performing pre-approval controlled functions within a regulated firm
4. The Minimum Competency Code sets qualification, knowledge and CPD standards for advisory staff, while Fitness and Probity covers the honesty, integrity and financial soundness of controlled functions

The MCC governs competency, knowledge and CPD for staff performing retail functions, whereas the Fitness and Probity Standards apply more broadly to controlled functions and test honesty, integrity, competence and financial soundness; neither regime replaced the other, and neither is confined to one sector or to PCFs alone. (Minimum Competency Code 2017; Fitness and Probity Standards (Central Bank Reform Act 2010, Part 3))

26. Under the Minimum Competency Code 2017 and the recognised CPD schemes, what is the minimum annual formal CPD requirement for an APA-accredited adviser, and what part of it must relate to ethics?

1. 15 hours in total, of which at least 3 hours must relate to ethics
2. 20 hours in total, of which at least 1 hour must relate to ethics
3. 15 hours in total, of which at least 1 hour must relate to ethics
4. 10 hours in total, with no specific ethics requirement

The MCC 2017 requires a minimum of 15 hours of formal CPD each CPD year, and under the recognised professional-body CPD schemes at least 1 of those hours must relate to ethics; neither 20 hours nor a 3-hour ethics allocation is required. (Minimum Competency Code 2017, CPD requirements (Central Bank of Ireland); recognised professional-body CPD scheme (e.g. Insurance Institute of Ireland / LIA), ethics hour)

27. Under the Minimum Competency Code 2017, a new entrant who has not yet obtained a recognised qualification may perform a retail insurance function only where their work is supervised by a person who meets which requirement?

1. A person who is themselves qualified and competent to perform that same retail function
2. Any employee who has worked at the firm for at least five years
3. A member of the firm's board of directors
4. The firm's external auditor

The MCC 2017 permits a new entrant to perform a retail function on a supervised basis only where the supervisor is qualified and competent for that same function; length of service, board membership or an audit role does not satisfy this requirement. (Minimum Competency Code 2017, New Entrant provisions (Central Bank of Ireland))

28. A new entrant has been performing a retail insurance advisory function on a supervised basis for four and a half years and still has not obtained a recognised qualification. Under the Minimum Competency Code 2017, what must the firm now do?

1. Extend the supervised period for a further four years automatically
2. Withdraw her from performing that retail function until the recognised qualification is obtained
3. Report the matter only, while allowing her to continue advising unsupervised
4. Allow her to continue provided she completes an additional 15 hours of CPD that year

Once the maximum permitted period for a new entrant (4 years) has elapsed without the qualification being obtained, she may no longer perform that retail function; extra CPD hours or continued supervision cannot substitute for the missing qualification. (Minimum Competency Code 2017, New Entrant provisions (Central Bank of Ireland))

29. What is the correct relationship between the CPD requirement under the Minimum Competency Code 2017 and the training requirement introduced by the Insurance Distribution Directive (IDD) in Irish law?

1. The IDD requirement of 15 hours replaced the MCC's CPD requirement from 2018 onward
2. Only the MCC imposes an annual training requirement; the IDD does not address training hours
3. The IDD sets a higher threshold of 25 hours, which supersedes the MCC's 15-hour requirement
4. They are two separate requirements that each independently prescribe at least 15 hours of annual training or CPD for relevant staff

The MCC 2017 (15 hours formal CPD) and the European Union (Insurance Distribution) Regulations 2018 implementing Article 10(2) IDD (at least 15 hours of professional training or development) are distinct, parallel requirements, not one replacing or exceeding the other. (Minimum Competency Code 2017; Directive (EU) 2016/97, Art. 10(2); European Union (Insurance Distribution) Regulations 2018 (S.I. No. 229 of 2018))

30. Under the Central Bank's Fitness and Probity Standards, which of the following is NOT one of the core standards expected of a person performing a controlled function?

1. Being competent and capable
2. Acting honestly, ethically and with integrity
3. Being financially sound
4. Holding a recognised professional qualification in law

The Fitness and Probity Standards require a person to be competent and capable, to act honestly, ethically and with integrity, and to be financially sound; holding a law qualification is not itself one of the prescribed standards. (Fitness and Probity Standards (Central Bank Reform Act 2010, Part 3))

31. Before permitting a person to perform a controlled function (CF), what must a regulated firm do under the Central Bank's Fitness and Probity regime?

1. Satisfy itself on reasonable grounds that the person complies with the Fitness and Probity Standards and obtain the person's agreement to abide by them
2. Obtain the prior written approval of the Financial Services and Pensions Ombudsman
3. Guarantee the person a minimum of five years' employment
4. Register the person personally with the Data Protection Commission

A firm must not permit a person to perform a controlled function unless it is satisfied on reasonable grounds that the person complies with the Fitness and Probity Standards and has agreed to abide by them; the FSPO, a minimum tenure and the Data Protection Commission play no part in this. (Central Bank Reform Act 2010, Part 3; Fitness and Probity Standards (Central Bank of Ireland))

32. By the end of October in her CPD year, an APA-accredited adviser has completed 11 hours of formal CPD, including 1 hour on ethics. How many further hours of formal CPD must she complete to meet the minimum annual requirement under the Minimum Competency Code 2017?

1. 3 hours
2. 4 hours
3. 5 hours
4. 1 hour

The minimum is 15 hours of formal CPD per CPD year; 15 minus the 11 hours already completed leaves 4 hours outstanding (her ethics hour is already satisfied). (Minimum Competency Code 2017, CPD requirements (Central Bank of Ireland))

33. An APA-accredited adviser fails to complete the minimum CPD hours required under the Minimum Competency Code 2017 within her CPD year. What is the most likely consequence under the Code?

1. The Central Bank of Ireland imposes a personal fine on her directly under the Code
2. Her complaint file is automatically referred to the Financial Services and Pensions Ombudsman
3. She is no longer treated as meeting the MCC's requirements to provide advice on the relevant retail products
4. Her firm's authorisation is suspended for a period of 6 years

Failure to meet the CPD requirement means the individual can no longer be regarded as satisfying the MCC's minimum competency requirements for the relevant function; the Code does not itself impose personal fines, trigger an FSPO referral, or suspend firm authorisation for a fixed period. (Minimum Competency Code 2017 (Central Bank of Ireland))

34. The Financial Services and Pensions Ombudsman (FSPO) was established under the Financial Services and Pensions Ombudsman Act 2017 through the merger of which two predecessor bodies?

1. The Insurance Ombudsman of Ireland and the Irish Financial Services Regulatory Authority
2. The Central Bank of Ireland and the Financial Regulator
3. The Financial Services Ombudsman's Bureau and the Office of the Pensions Ombudsman
4. The Pensions Board and the Consumers' Association of Ireland

The FSPO Act 2017 merged the Financial Services Ombudsman's Bureau and the Office of the Pensions Ombudsman into a single body; the other pairings name real but unrelated Irish bodies. (Financial Services and Pensions Ombudsman Act 2017 (No. 22 of 2017))

35. On what date did the Financial Services and Pensions Ombudsman commence operation under the FSPO Act 2017?

1. 3 January 2018
2. 1 January 2018
3. 1 January 2017
4. 1 January 2019

The FSPO began operation on 1 January 2018; 3 January 2018 is instead the effective date of the unrelated Minimum Competency Code 2017 and Regulations 2017. (Financial Services and Pensions Ombudsman Act 2017 (No. 22 of 2017))