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Product Governance

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


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, RPPD and COBS
Defining terms – distributors and manufacturers – differences in their duties

Systems and controls and governance

Core risk management for products and their governance
Joined up independent review & challenge
Developing a governance structure for products generally and stress testing
Who, what, when?
Ongoing review of products and their MI
Differences in duties of distributors and manufacturers

The tasks

Identifying the target market
Working out who the product is suitable for and who it is not
Working with distributors and others on target markets – research, focus groups
Different roles of providers and distributors

Core design issues
Building a specification
Drafting the terms and conditions
Common fund and wrapper issues – investment content, charges
Ensuring that service infrastructure is in place

Stress testing
Method – what is there to test against?
Resilience – technologically, financially and other elements

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
Assess compatibility of product with customers
Best interests rule
Obligation to obtain material from manufacturers
Handling distribution chains
Identify target market and distribution strategy suitable for its clients’ needs, characteristics & objectives
Periodic review
Information sharing with manufacturers
Sales outside target market

Product material
Clear, fair and not misleading
Material for distributors
Key features and other mandatory material

Post-launch 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
Ongoing review and acting on information
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.