Product governance

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Product Governance

FBC has a strong track record of supporting its clients in Assessment of Value (AoV) reviews, arguably a subset of the bigger theme of product governance, an ongoing process within fund management firms.  We are expanding our focus to look at product governance and distribution governance in response to increasing FCA attention in these areas and to help our members and clients get onto the ‘front foot’ when it comes to the FCA’s new Consumer Duty.  Alongside our corporate membership programme, which includes regular events with regulators, FBC advises and consults with both members and non-member firms on a range of product and distribution governance topics and challenges that their fund boards are addressing.  

In 2023 we will also be adding a new area of focus on Operations Governance, with the development of a series of initiatives on the governance of fund operations

Brandon Horwitz
Brandon Horwitz
Senior Adviser and Non-Executive Director

Regulatory Environment

Fund managers are already subject to product governance rules applied by the FCA as part of implementing MiFID II. Technically these rules do not apply to Authorised Fund Managers (AFMs) managing UCITS schemes. However, the rules have been applied as guidance to AFMs, with firms expected to behave as if they are subject to the rules.  The FCA’s new Consumer Duty, expected to be in force from April 2023, will apply even broader product governance requirements to all authorised firms, including AFMs.  Fund managers are explicitly mentioned in numerous places in the latest consultation (CP21/36, Dec 2021)

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Our insights and services include:

AoV Reviews

FBC offers three levels of Assessment of Value reviews, from the AoV Review with an FBC expert (included with corporate membership) to a full Assurance Review with feedback aligned to regulatory requirements. 

AoV Reports

Our unique databank of over 250 AoV reports. This service is regularly updated and available ondemand exclusively for FBC corporate members. 

Fund Board Assessment Review

Highly customisable review of the fund board effectiveness and efficiency, tailored to the specific requirements of an individual fund.  


Expert led and available as a bespoke and off-the-shelf service, our training is designed specifically for fund board members including executive and non-executive directors. and senior executives who support the board on a regular basis. 

FBC Operations Governance Services in 2023

Service Provider Oversight – research, workshops and benchmarking

FBC will be developing a series of initiatives to support fund boards in discharging their service provider oversight duties. This includes a detailed research study exploring this topic, findings from which will be shared with FBC members and will form the basis for a series of dedicated, bespoke Service Provider Oversight workshop sessions and benchmarking.

Risk Management Oversight – research and engagement

In 2023, FBC will be conducting research into key aspects of how fund boards are approaching risk management oversight including areas such as operational resilience and liquidity risk. 


The Fund Boards Council (FBC) Report: Distribution Oversight

Key questions and best practices

Distribution oversight has become an increasingly important topic on the fund governance agenda in the UK and across Europe. In Luxembourg and Ireland there are clear regulatory expectations that must be adhered to and, most recently, the UK’s new Consumer Duty announced last month (July 2022), includes a strong focus on consumer understanding and consumer support. Distributor oversight will be key to meeting these new obligations, especially as most funds are distributed through intermediaries and platforms in the UK.

The FBC Report: Distribution Oversight Key Questions and Best Practices includes unique proprietary research covering distribution oversight across multiple fund structures. The research was undertaken via in-depth interviews with both executive and non-executive directors sitting on fund boards, as well as with other related professionals across functional areas. The fieldwork for the FBC Report: Distribution Oversight covered the three key money centres of Europe: the UK, Luxembourg and Ireland, following initial interviews highlighting that many fund groups with UK and ‘offshore’ UCITS fund ranges sought to apply a holistic approach to governance across all their fund ranges.

The report contains findings in key areas including:

  1. Roles and responsibilities for distribution oversight in fund management organisations
  2. Key challenges in undertaking distribution oversight in the main fund jurisdictions
  3. Common features and differences in the key regulations – today and looking forward – covering distribution oversight across the jurisdictions
  4. Examples of good practice which we could share.


Read some key excerpts of paper here


Managing fund liquidity in 2022

Impact of the Ukraine war and rising interest rates and inflation

FBC welcomes back Sebastjan Smodis from State Street Global Advisers who we spoke with in 2021 on the theme of a ‘liquidity risk playbook’ which firms could use to manage fund liquidity. FBC corporate members can view this on demand in the FBC member portal here.

A lot has happened in the year since we last spoke with Sebastjan, with market volatility and geopolitics certainly making sure that firms will have been putting their liquidity risk playbooks to good use!

In this podcast, Brandon Horwitz, FBC Senior adviser, discussing with Sebastjan how fund managers have been reacting to events over the past year including: the impact of the Ukraine war, rising interest rates and inflation (and the impact on fixed income investments) and the continuing impact of Covid-19. Another key theme is the role of fund boards in overseeing liquidity management activities in the past year, including how they have interacted with executive teams in and outside of board meetings.


Exploring distribution oversight and best practices

May 2022

At this FBC members digital event. FBC adviser Simon Hynes, was joined by three distribution experts:

  • Birgit Sammer, Head of Distribution Oversight/Conducting Officer, Invesco Management S.A.
  • Chris Town, Deputy Head of Compliance at Columbia Threadneedle Investments
  • Laurence Mumford, Distribution Governance Director at M&G plc.

To view the recording of the event and related materials, click here.


Framing the Agenda: In Conversation with the FCA

December 2021

Read the write-up of our FBC members event with the FCA here.

FBC members can hear the full meeting here.

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