Consumer Duty Bulletin Part Five: Links in the Distribution Chain
In this Consumer Duty Bulletin we provide an overview of the requirements to share information on the output of both product governance and fair value assessments with distributors.
We look at how to develop distribution strategies, the information that manufacturers should share, the role of distributors, what manufacturers should consider asking distributors about and information distributors should ask for.
There is no single prescribed approach to meeting the Duty, so manufacturers and distributors do have a high degree of flexibility to develop processes, procedures and information sharing that works best for their products and distribution chains.
All firms should look at what information they currently share and consider how helpful this is in meeting the Duty. For example, parties in a mature distribution arrangement may find they have less to do where they already regularly share sales and satisfaction MI with each other, have clear communication of product information (and associated conduct risk management requirements) and share output from their own internal reviews of how products and sales processes are functioning.
For a proportion of firms, preparing for Consumer Duty may be as much about enhancing existing arrangements as it will be implementing new processes and procedures.
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Auxillias Consumer Duty Toolkit
We have developed a toolkit to help clients to prepare for Consumer Duty and hit the key milestones of 30 April 2023 and 31 July 2023. It currently includes:
1. A number of high-level templates, example of processes and documentation to help firms define their own key processes under Consumer Duty.
2. Post-implementation assurance reviews immediately following the key implementation deadlines in April and July.
3. Advice on identifying manufacturers, distributors, co-manufacturing relationships.
4. A series of training packages on Consumer Duty for lenders and brokers/retail dealers.
5. Support and guidance on the governance aspects of the consumer duty - including drafting new policies and procedures, reviewing governance and reporting arrangements and senior management oversight and assisting you with the required changes to your Senior Management and Certification Regime arrangements.
If you are interested in finding out more, about our Toolkit please register your interest via this link and we will be in touch.