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The following article was published in our article directory on October 31, 2016.
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Senior Manager's Regime: Best Practices To effectively manage product governance together with the product lifecycle

Article Category: Business Management

Author Name: Lee Werrell

Senior Manager's Regime: Best Practices To effectively manage product governance alongside the product lifecycle

Whatever Way You Examine It ... It Is A Tough Nut To Crack

Throughout the original journey to the FCA, the transfer of focus was distinctly from being a reactive to a proactive approach. The regulator is in fact attempting to stop customer detriment before it transpires where possible.

A vital element of the regulator's attention focuses on products consequently we have experienced a marked rise in concentration paid to product governance and product life-cycle management over the last three years since the regulator started.

A central question firms should really answer is precisely how, looking at Conduct Risk and TCF, how they will guarantee and can adequately demonstrate they have put the consumer at the heart of their businesses. The FCA expects firms to be capable of demonstrating this in the context of all product and related, complimentary or auxiliary activities. Our company has also noted a large volume of Risk Mitigation Plan requirements concerning product governance, and questioning the robustness of the governance and approval arrangements, suggesting that this has become a potential hotspot for Boards and senior management.

There have already been numerous regulatory developments in this particular field previously even from the 2013 FCA Risk Outlook that confirmed that a priority to the regulator is that firms design services and products that respond to real consumer needs and remain in their long-term interest. Although the most recent Business plan for 2016/17 does not spell it out, the firm's culture and governance, incorporating the proficiency of independent governance committees (IGC's) is likely to include product lifecycle. Various thematic reviews concerning product, such as the publication on smart phone insurance, which underline the significance of a product with the FCA and therefore this has to be related to culture and governance, ergo a firm-wide matter.

Whilst we don't anticipate seeing a broad use of product bans, we are seeing a greater programme of product governance reviews being launched by the FCA. Additionally it is very clear whenever action is initiated in respect of product intervention by FCA, there will undoubtedly be reputational and commercial impacts, to firms and their culture and overall governance will be investigated.

Actually, such powers will permit the FCA to:

Restrict the distribution and sales of certain product features;
Stipulate that a product is not marketed to some or all specific forms of customers; and
In possibly the most serious cases-- mandate that a product is removed from sale altogether.

These requirements pose some real demands for firms establishing, managing and reviewing their product governance and life-cycle approaches.

" How Many Holes Exist In Your Cheese?"

Examples of the key questions and challenges include:

Product and Customer Methods

Have you got appropriately senior and experienced people involved with the setting of product strategy, having a sufficient and appropriate customer-centric approach?
Can you demonstrate that you have appropriately considered the suitability of all distributors for your products and fully understand their actions and are reassured with the customer journey?

Committees To Deal With The Product Approval, Review and Governance Process

Is there a demonstrably suitable balance of committee membership, having a clear and identified "voice of the customer"?
Does there exist adequate documented evidence of customer-focused review and challenge?

Suitable Product Development and Approval Criteria

Do your processes and operational procedures generate clear identification of your target market and demonstrable customer needs for every single one of your products?
Are customer risks considered at an appropriate stage and sufficiently early enough during the product development process, including appropriate customer involvement while in the product design process?

Exactly how do you demonstrate evaluation of product-related risks for your customers, such as distribution strategies, using third-parties, product sophistication or complexity and customer value?

Product Review Processes

Can you be certain that your particular products remain suitable as time passes for your target market and current environment by which they are sold?

Product Governance

Does your Board demand and receive the right MI to successfully monitor the product development to enable it to intervene where needed?

Regardless of what your needs are, we can provide an objective and detailed review of the evidence and assist you in plugging any gaps you may have.

Just call us on 0207 097 1434 or email [email protected]

Keywords: senior managers regime, certification regime, product governance,financial conduct authority

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