Not Just a Pandemic Assessment
The FCA have begun a review of the effectiveness of the product governance process in a small sample of firms (insurers, brokers and MGAs involved in product manufacture). The review is looking at the way firm’s product governance processes have responded to the pandemic. ICSR has seen the information and data request sent by the FCA and it is a comprehensive response that is required of firms, beginning with identification of the Senior Management Function holder responsible for product governance. There is an unveiled warning in the approach taken.
It is clear the FCA are using the pandemic as an opportunity to benchmark product governance and product value processes and establish if remediatory action is required. It is our advice that even if you are not one of those firms contacted by the FCA, you should use the opportunity to undertake a review of the way your firms processes have responded.