Product Governance Value Policy Guidance Manual


Ecompli supports several General Insurance Brokers who are involved in the manufacturing and/or distribution of general insurance so we produced a Product Governance Value Policy Guidance Manual back in September 2020.  This included guidance on what firms should consider when manufacturing and/or distributing insurance products to ensure that they met the fair value requirements.

Since then we have continually updated the manual including ensuring it meets the Consumer Duty requirements which affects all products and services sold or renewed from the 31st July 2023.

The manual includes guidance to assist firms to assess the design and distribution of products and services and to ensure they are fit for purpose and are a fair value.  It can also act as evidence to Insurers that the firm has taken on board the FCA requirements under the Product Governance rules, the Consumer Duty and the culture it has embedded.

FORMAT: All documents are downloadable via email upon receipt of payment.


INDEX OF CONTENTS – 24 Pages – Updated with Consumer Duty requirements – July 2023 

  1. Introduction
    1. Principle 12 – Consumer Duty
    2. Consumer Duty Responsibility
    3. Senior Manager Responsibility
  2. Guidance for Insurance Product Manufacturers
    1. Product Manufacturing
    2. Co-Manufacturers
    3. Product Distribution Strategy
    4. Price and Remuneration
    5. Management Information – Risk Assessment of Fair Value
    6. Fair Value Product Review Requirements
    7. Record Keeping
  3. Guidance for Insurance Product Distributors
    1. Price and Remuneration
    2. Premium Finance
    3. Arranging Premium Finance
    4. Management Information
  4. Pricing Remedy – Consumer Home & Motor Insurance
    1. Discounts / Incentives / Commission Sacrifice
    2. Anti-Avoidance Rules
    3. Additional Products and Premium Finance
    4. Closed Books
    5. Attestation and Record Keeping Requirements
    6. Home and Motor Reporting Requirements
  5. Auto-Renewal (General Insurance)
    1. Policies Excluded from Auto-Renewing
    2. Auto-Renewing Rules
    3. Vulnerable Customers
  6. Unacceptable Examples of Poor Value and Service
    1. Example 1 – Tour operator travel insurance products for coach trips
    2. Example 2 – Claims services being provided under delegated authority
    3. Example 3 – GAP Insurance
    4. Example 4 – Scratch and Dent Insurance
    5. Example 5 – Tradesman Insurance
    6. Example 6 – GAP insurance potentially sold to ineligible customers or those who do not need cover
    7. Example 7 – Failure to fulfil obligation – Travel insurance and scratch and dent insurance