With the FCA stating earlier this year that it will turn its attention on how firms are implementing new rules around product governance, advisors would be wise to review how they are complying with PROD (Product Intervention and Product Governance Sourcebook) which came into force rather under the radar with MiFID II in January 2018. This was extended to insurance in October.
Starting in 2008 with RPPD and now with PROD, the regulator has imposed an extra layer of duties on advisers and providers to ensure that the products that they make and distribute are suitable for the type of people like to buy them. Most of the major financial services scandals since 2000 have involved products not designed to help those buying them. The FCA is increasingly concerned to ensure that reasonable quality products end up in the right places.
At its heart PROD requires advisors and providers must demonstrate to the regulator the cost, service and investment proposition they are recommending are appropriate for each client segment. It is important for both groups to avoid another unregulated collective investment scheme, life settlement fund, pension transfer or whatever problem is coming around the corner.
This practical one day workshop prepares you to meet your obligations under PROD helping you make any changes to products and services that you offer, so that by the end of this workshop you will be able to:
- Know how to find PROD and its updates
- Know how PROD interacts with the FCA Principles, the COBS rulebook and RPPD
- Build effective product governance arrangements
- Identify target markets
- Obtain, apply and review stress test results
- Know how to learn how products work
- Limit sales to target markets and tell providers of issues in that area
- Exclude inappropriate products for your distribution method
- Review the workings of a product and your distribution of it
Adam Samuel is a compliance specialist and lawyer who has spent much of the last 20 years advising firms from major banks to small one-man firms on conduct related issues. Qualified as a lawyer on both sides of the Atlantic and proud holder of an AFPC, MAQ and CISI compliance diploma, Adam wrote the only major book on financial services complaint handling in 2005, now in a 2017 second edition.