Consumer Duty - Product Governance

This is the first of a series of articles looking at the Consumer Duty and its implications for the wealth management world. The distribution chain can be extremely complicated and consist of multiple product manufacturers (both for the actual investments and associated wrappers), platform provider, custodians, DFM, broker and/or financial adviser. Some will play a relatively minor role whereas others' will be significant.

The Consumer Duty consists of an overarching principle, cross-cutting rules and outcomes. As such, there is not just one section or obligation that firms need to comply with when considering product governance and their distribution chains. However, the most immediately applicable is the new 'Product and Services Outcome'. We explore how this Outcome works with the current PROD rules, some of the key requirements firms will need to consider and what it means in practice.