Programme: How to Undertake FCA Regulated Product Reviews

• Failure of regulation at the point of sale
• The FCA’s new focus and objectives
• Firm cultures and business models
• Principles-based regulation and TCF Outcomes
• The impact of the SM&CR
• The impact of the Consumer Duty
• The FCA’s focus for enforcement
• The IDD – product governance and customer best interests
• The PROD Sourcebook
• The FCA’s wider focus for oversight over product value

 Session 2 – Getting your firm into shape

 Reviewing your business model

• Reviewing your culture and consumer focus
• Reviewing senior management oversight
• Reviewing what role your firm plays in product development
• Who is a manufacturer?
• Who is a distributor?
• Joint manufacturing
• Reviewing systems and controls
• Reviewing internal & external information
• Understanding the regulatory risks

 Session 3 – Planning your product reviews

 Where to start?

• The core PROD obligations
• How the Consumer Duty will impact
• The processes to be followed
• Who should be involved?
• The role of the Product Review Group
• When, and how often?
• Which products, in which order?
• The product database
• Identifying and measuring risk
• Regulatory monitoring
• Setting priorities

 Session 4 – Undertaking Product Reviews (1)

 The three phases of a review

• The Assessment Phase
• The four risks to be reviewed
• Assessing your customer risk
• Identifying your target market
• Testing the target market
• Assessing your product risk
• Product complexity & documentation
• The Consumer Understanding outcome
• How to undertake a fair value assessment

 Session 5 – Undertaking Product Reviews (2)

 Assessing your sales & distribution risk

• Oversight and control of distribution
• Key risks to fair value in distribution
• Assessing fair value in distribution
• Supporting distributors
• Assessing your service risk
• Meeting the Consumer Support Outcome
• Integrating complains and feedback
• The customer perspective
• Customer challenge
• Your Product Review Report

 Session 6 – Decisions and Remedial Actions

 The Decision Phase

• Rectifying product risk
• Remedying product risk
• Existing products versus new products
• Meeting PROD obligations
• Remedies in the distribution chain
• Principle 11 and SUP 15
• Engagement with the FCA
• The Implementation Phase
• Implementing change
• Management/Owner issues
• Entrenched positions
• Putting Product Reviews in a wider context

 Question & Discussion Session