15 When distributing financial instruments, how should our firm determine a distribution strategy and ensure the strategy is appropriate for the target market? As a distributor you must ensure that the products and funds you wish to include within your proposition are broadly consistent with your target market of clients. This is an existing product governance requirement that is echoed in the Consumer Duty. Obtaining information from the manufacturer should be relatively straightforward as most fund groups use the product manufacturer’s European MiFID Template (EMT) to state the appropriate distribution strategy, from the perspective of the manufacturer. For example, whether a product should only be sold with advice, or whether (for non-advised sales) the product in question requires an appropriateness test. Other factors should be considered alongside based on your knowledge of your own client base. For example: • Should the product only be recommended by specialist advisers? • Should the product be withheld from certain categories of vulnerable client? • Does the product or service trigger a conflict of interest for clients in the target market? • Will all of the available product options or add-ons be made available to the firm’s clients or should you restrict some? You should regularly review your distribution arrangements to ensure they remain appropriate. Where issues are identified, you should take appropriate action to mitigate the situation and prevent any further harm. This may involve the firm sharing relevant sales information with manufacturers. Commonly asked questions
RkJQdWJsaXNoZXIy NjM2Njg1