12 How to achieve FCA requirements Points to consider Can you demonstrate, with appropriate evidence, that your firm: Specific examples as to how to achieve this These examples will not be relevant to all firm types Fully understands its PROD obligations as a distributor? • A documented product governance policy is in place and is regularly reviewed in Compliance, Board or Investment Committee meetings. • The firm has identified a distribution strategy for each product/service to ensure the product/ service is distributed appropriately. For example, complex products are recommended over three appointments. Less complex solutions are delivered online or by remote consultation in one or two appointments. • Use of a documented Advice and Investment Process, with special emphasis on higher risk products, such as Equity Release / VCT / EIS. Use third party expertise where appropriate. • Use of a Centralised Retirement Income Proposition (CRIP) decumulation process. • Staff training records on how the firm selects funds/products/platforms. Can extend its PROD obligations to all retail products and services that clients may use? • Documented advice and admin process covering all products and services offered, such as an annual pension review process or mortgage review processes. • Providing staff training on how the scope of PROD rules differs from the scope of the Consumer Duty.
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