Professional Documents
Culture Documents
►► Instructions to amend products ahead of launch ►► Restricting the promotion of products to certain
consumer groups
►► Requests for copies of product governance processes
►► Requiring a product to be removed from the marketplace
►► Requests for explanations and clarification of
product features The illustrative life cycle shown below is indicative of the stages
in a product’s life cycle where controls are needed. It is not
It has also been given new statutory powers to ban products on
designed to be exhaustive but indicates the approach firms
a temporary basis without consultation. Product intervention
should take in terms of the development and management of
will apply across the life cycle of a product, and firms will need
their product portfolios.
defined controls in place to manage products at every stage.
Product
development
Business
Investor
Corporate Product
Mo
customer protection. However, “waves of major customer level risk level risk
detriment”, such as PPI and endowment mis-selling and interest
rate hedging products, show that reactive regulation has not been
sufficiently effective. Product review Business Product life
Product intervention is based on the premise that disclosure is not
sufficient given consumer behaviors. It is about moving toward
being proactive rather than reactive. The ultimate intention is
to complement the traditional focus on sales and marketing
“The FCA will have a fundamentally different approach
and the disclosure of information throughout the product life
cycle. The product intervention regime recognizes that decisions to that of the FSA in the way it intervenes to mitigate
taken by firms when designing new products, and managing risk to financial services. The FCA will have a lower
existing products, have an impact on subsequent distribution and
risk appetite for issues affecting a whole sector, sub-
consumer outcomes. The interventionist regime will apply to all
product types and sectors. sector or type of product — it will be less prepared to
Product intervention is an integral part of the FCA’s consumer see detriment actually occur, instead seeking to act in
protection strategy, which is closely aligned to what is happening a more preventative manner.”
throughout Europe. It is designed to ensure the retail market works
Product Intervention Feedback on DP11/1
better for consumers and to increase confidence in the financial
services sector. Firms need to be prepared for the challenge.
In addition, products that are closed to new business but are open
for existing customers to “top-up” or switch from will also need
to be considered in light of current regulatory standards and
managed appropriately, where applicable.
Firms need to pay particular attention where legacy products are
outside their current product strategy or where products are sold to
groups of customers that do not fit their strategy for ongoing market
penetration. These issues may result in the firm taking on customers
whose needs they are unable to address in the longer term, or
whose expectations may not be met by either the product they have
purchased or the service they receive. The current low-interest-rate
environment in the UK is bringing this issue to light as investors
move out of deposits into structured and other products that carry
an increased investment risk to chase potentially higher returns.
Closure
instigation one build two review checkpoints identification
Product Market testing Distribution Training — sales Servicing issues Sales vs. target Ongoing client
specification outcome strategy ratified and service identified market review management
Go/no go Go/no go
decision decision
Defined governance process including stress and scenario testing and profitability reviews
Insurance firms
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