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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.  

We’ve also added 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 Consumer Duty, that was put in force from April 2023, applies 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).

PRODUCT GOVERNANCE

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. 

Fund Board Assessment Review

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

Training

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. 

Distribution Governance

FBC has built on its existing proprietary research into key distribution oversight challenges for fund boards with a programme of activities to help fund boards address regulatory developments such as Consumer Duty. 

FBC Distribution Governance Services

Proprietary Research

New FBC research will examine how fund boards engage with their firm’s distribution professionals, looking at challenges around data provision to the board and oversight of areas such as distributor due diligence and client liquidity.  This research will be available exclusively to FBC corporate members, along with key considerations framework they can take away and consider with their own boards, and invitations to dedicated members’ meetings on this topic.

Distribution Governance Effectiveness Workshops​

Based on the insights from FBC’s proprietary distribution governance research, we will  run a series of workshops for distribution professionals to support them in their engagement with the fund board. 

The workshops are available for individual member firms and provide a confidential forum to get an independent, expert view on their approach to board discussions, the effectiveness of data and materials presented to board directors and how to make best use of distribution discussions in board meetings. 

DISTRIBUTION OVERSIGHT

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 Consumer Duty announced in July 2022, includes a strong focus on consumer understanding and consumer support. Distributor oversight is key to meeting these 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 the paper.

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