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- Robert Bell
Actioning Product Reviews
With the deadline to mitigate findings from open product reviews fast approaching, remediation plans should now be in full swing. As you’ll know, we have until 31 July 2023 to correct harms identified as part of our product reviews, otherwise we must stop circulating the product (PRIN 2A.3.10 R). Timely action is imperative.
However, what we are seeing in the market is not wholly positive. Whilst some firms got ahead with their implementation plans early in the journey and are therefore now working through identified issues, others are struggling to get their head around what the reviews should cover, let alone how to tackle issues.
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PRIN 2A.3 sets out the required content of a product review, so as you conduct your reviews be sure to work through PRIN 2A.3 and cover each required area or use our template to assist you. What we have found works best is to take a step back from the technical requirements to get a better feel for the purpose of the review. The goal is to identify potential harms that could be caused by your product to customers as well as instances where your product has not been designed in good faith and situations where the product might not help the customer to pursue their financial objectives.
Examples include:
Customer onboarding processes which include pressure points designed to rush a customer’s decision
A lending product aimed at sub-prime customers where the affordability assessment is not robust enough to pick up all instances where a customer is uncreditworthy
Communication which has been designed to be understood by the average person, however the product is aimed at customers with a lower reading age or level of education
Onboarding processes which don’t provide the customer with the full set of information - at the right time – that they need to make an informed decision
Where it is difficult for customers to obtain support from the company after the point of sale
Poorly embedded vulnerable customer procedures
Once you have identified the potential harms, instances where it could be argued you’re not acting in good faith, etc. then you are able to move onto mitigation. Mitigation may include:
Changing the timing of your customer communication, to point out risks in a timely fashion so customers are able to make choices with all the information to hand
Changing the content of your communication, so that it is understandable for your target market, for example simplifying wording where your target market has a lower average reading age
Improving the structure of your onboarding process, adding a ‘brake’ to allow customers to consider whether the product is right for them
Improving your MI provision to identify trends in customer usage, drop-off rates and how this impacts vulnerable customers
These are only a few suggestions, but now you should be working through your own list.
On that note we have updated our product review template to include guidance on each section, we have also streamlined the questions. The new template can be found in the Consumer Duty Resources section of our website.
