In this latest podcast and transcript dedicated to the Consumer Duty, FCA Head of Competition Policy Ed Smith talks about the FCA’s expectations for manufacturers to complete and share their products and services reviews by 30th April 2023, and the reasons behind this milestone. Smith emphasises the need for firms to work together, and talks about the requirements for information sharing after the Duty comes into force in July, including what should happen in the case of any disagreements within the distribution chain.
Smith outlines the importance of all the firms along a distribution chain working together and pulling in the same direction with a shared goal of delivering good outcomes for consumers. In addressing the 30th April deadline for manufacturers (which for insurance should not need as a milestone, with the existing product governance and fair value requirements already being in force), Smith explains that all parts of that distribution chain need to be in compliance by the end of July but that there are things that manufacturers will need to do first. This perhaps indicates the FCA’s expectations that the ’first steps’ in any product governance process need to be taken by the manufacturers.
The message in the podcast is clearly one of cooperation and engagement between all elements of the distribution chain, and the FCA’s expectation is that this should continue after the July 2023 deadline. The current requirement in insurance for regular product reviews is mirrored in the Duty for all firms. Smith indicates that, if things significantly change with a product, or if new marketing material is developed (perhaps looking at target market considerations), those could be the occasions on which manufacturers review or re-review the product in question, passing the details of that review down the line through the distribution chain.