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Product Governance – Insurance

two half days including the use of case studies from the company and beyond


Welcome and Introduction

Learning objectives and programme

Finding the relevant parts of the PROD rulebook

Insurance Distribution Directive, article 25, POG Regulation, articles 3-9, EIOPA Guidelines, PROD 4

TCF and the 6 outcomes and their application to products

FCA & EU powers to issue product intervention rules and intervene generally

Relationship between PROD, RPPD and ICOBS and COBS (for long-term insurance and pensions)

Defining terms – ‘product governance’, ‘distributors’ and ‘manufacturers’ and why it matters


Part 1 – The building blocks of product governance


Systems and controls and governance

What arrangements do the rules require?

Building the necessary product governance structures

Who, what, when?

Independent review and challenge

The role of the product governance team or ongoing monitoring function


Product governance work and approaches

The different types of review required

Ongoing monitoring – who and how?

Core risk management for products and their governance

The role of compliance and senior management

Joint manufacturers

Conflicts of interest


Part 2 – The tasks


Identifying the target market

Working out who the product is suitable for and who it is not

Ensuring that value is delivered to the target market

Different roles of providers and distributors – and different target markets


Core design issues and value measures

Building a specification


Value measures – defining value for money and the period of time involved

Value measures reporting categories and other relevant criteria for determining value

Drafting the terms and conditions

Common fund and wrapper issues – investment content, charges

Ensuring that service infrastructure is in place


Product testing

Method – what is there to test against?

Resilience – technologically, financially and other elements

The testing process and its governance


Distribution channels

Selection – internally and externally, technologically, advised or execution-only

Monitoring distributors’ behaviour

Working with IFAs and others

Assessing the value to the end customer of a product sold along a distribution chain

Changing or blocking distribution channels


Distributor Responsibilities

Know your product

Obligation to obtain material from manufacturers

Handling distribution chains

Identifying and following target market and distribution strategy suitable for its clients’ needs, characteristics & objectives

Periodic review

Information sharing with manufacturers of sales outside target market and generally


Product material

Clear, fair and not misleading for customer material

Different standard for intermediaries-only material

Materials for distributors about the product review process


Product reviews and monitoring

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

Researching the product and how it is being used

Ongoing monitoring and acting on information

Managing failures – communication to customers and regulators, product withdrawals and compensation arrangements






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.