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Product governance in the EU

two half-days with case studies – for product governance, risk managers and compliance staff




Defining product governance

Finding the key materials

MiFID 2, Arts. 9 & 10 MiFID Delegated Directive

Insurance Distribution Directive, article 25, POG Regulation, articles 3-9,

ESMA, EBA & EIOPA Guidelines

National rules

EU powers to issue product intervention rules and intervene generally


The product governance arrangements & structures


Building the product governance arrangements

Who must be there doing what?

Doing the product governance work

Role of senior management and compliance

Basic risk management for products

Reviewing the procedures

Different forms of product reviews and ongoing monitoring


The tasks


Identifying the target market – positive and negative

Working with distributors and others on target markets – research, focus groups

Different roles of providers and distributors


Core design issues

Building a specification

Modelling – value measures

Drafting the terms and conditions

Common fund and wrapper issues – investment content, charges

Ensuring that service infrastructure is in place – outsourcing


Product or Stress testing


Method – what is there to test against?

Resilience – technologically, financially and other elements

Testing governance


Distribution channels

Selection – internal and external, technologically diverse, advised or execution-only

Monitoring distributor behaviour

Working with distributors and affiliate marketers

Changing or blocking distribution channels


Distributor Responsibilities

Know your product

Assess compatibility of product with customers

Obligation to obtain material from manufacturers

Handling distribution chains

Information sharing with manufacturers

Sales outside target market


Product material

Clear, fair and not misleading

ESMA measures on contracts for differences

Material for distributors


Post-launch and ongoing review

MI on customer types and distribution sources – lapses, complaints and claims

Researching the product and how it is being used

Distributors’ role in amending target markets

Managing failures – communication, withdrawal and compensation

Get in touch

Contact Adam by e-mail, phone or post at:

E-Mail: or

Mobile: 07900 248150

The Attic, 117 Priory Road, London NW6 3NN.