General insurance product governance: from supervisory neglect to overkill?

In a recent review of non-investment insurancethe Financial Conduct Authority "has woken up to what it always assumed was a sleepy backwater of its activities and found some highly undesirable activities". The regulator's opinions sometimes go well beyond what its rulebook says and what can sensibly be achieved by a corporate board in practice, commentsAdam Samuel.

Adam SamuelBA LLM DipPFS MCISI FCIArb Certs CII (MP&ER) Barrister and Attorney may be contacted atadamsamuel@aol.com.You can purchase Adam's latest book 'Compliance - a Short Book' atwww.amazon.co.uk/Compliance-Short-Book-Adam-Samuel-ebook/dp/B0CTRYBN1J/. For links to where you can buy the second edition of 'Consumer Financial Services Complaints and Compensation', seewww.adamsamuel.com/writing.

March's thematic review on retirement income (TR24/1) can be seen as the Financial Conduct Authority rewriting the product governance rules for investments and pensions. To follow this up, August's TR24/2 - 'Product Oversight and Governance thematic review - General Insurance and Pure Protection' - does much the same thing for non-investment insurance. In their slightly rambling way, these two documents have become crucial to an understanding of how the FCA sees PROD 3 and 4 as well as product governance generally, notably for the purposes of the Consumer Duty.