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Product Governance – Investments and Pensions

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




Finding the relevant FCA Principles & PROD rulebook

MiFID 2, ESMA guidelines, Art. 9 MiFID Delegated Directive, PROD 3

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, PRIN 2A (the Consumer Duty) and COBS

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


Part 1


Product governance structures


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 activities and approaches


The different types of review required

Core risk management for products and their governance

The role of compliance and senior management and reports to and by them

Joint manufacturers

Identifying and managing 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

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 distributor behaviour

Working with IFAs and others

Changing or blocking distribution channels


Distributor Responsibilities


Know your product and the obligation to obtain material from manufacturers

Handling distribution chains

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

Remaining within the manufacturer’s target market and distribution strategy

Dealing with products with no manufacturer target market and distribution strategy

Periodic review

Information sharing with manufacturers – co-operation and reporting sales outside target market


Product material


Clear, fair and not misleading for customer material

Communications Outcome of Consumer Duty

Different standard for intermediaries-only material

Material for distributors

Key features and other mandatory material


Post-launch and other reviews and ongoing monitoring


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

Researching the product and how it is being used

Ongoing review 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.