Product governance.
Information on our product governance process.
Product Approval Process
First Title Insurance plc has a Product Approval Process which is reviewed/updated on a regular basis to reflect the needs of the business and the expectations of our key stakeholders.
The Financial Conduct Authority (FCA) requires us to provide appropriate information on our product approval process to distributors. Our product approval process applies to all new products, as well as to products that have been significantly changed. Significant changes of existing insurance products include, but are not limited to, a proposed change to the insurance coverage, standard pricing, exclusions, excesses, limits or conditions and any other significant change to the terms and conditions. In these circumstances, the review will also include consideration of the potential impact the changes may have on an existing or potential customer.
Our product approval process:
- Puts customers at the heart of the process
- Is fully compliant with all regulation and legislation
- Is simple and efficient
- Is commercially minded
- Is flexible and agile
- Identifies the target market
- Ensures products provide fair value
Where a distributor charges fees or commissions to the customer, the assessment must consider whether that adversely impacts the overall value received by the customer. For this reason, and in order to comply with our regulatory obligations, we require our distribution partners to provide information about any additional remuneration paid by the policyholder and to demonstrate how it supports fair value.
In the unlikely event of a product not offering fair value to customers, we will take all reasonable steps to remedy the issue and to put policy holders in the position they would have been in had the product offered fair value. We will continue to monitor and update the Fair Value Assessments (FVAs) to ensure the fair treatment of customers and to adhere to market standards.
Our product approval process details the methodology and type of metrics we consider when conducting our FVAs. Our products are reviewed at least annually.
If you have any questions regarding Product Governance, please contact us at: compliance@firsttitle.co.uk
Fair Value Assessment Process (VFA)
Our Fair Value Assessments (FVAs) consider at least:
- The intended target market of the product
- The nature of the product including the benefits, their quality and any limitations
- The type and quality of services provided to customers
- The expected total price to be paid by the customer when buying or amending the product
- How the intended distribution arrangements support fair value
It also considers a range of indicators and metrics such as:
- Commission rate
- Loss ratio
- Claims frequency
- Claims repudiation rate
- Customer complaint ratio
We will share the outcome of our FVAs, in line with the FCA guidance, but will not be sharing the actual detail contained in the FVAs as these are confidential documents that we are unable to share for commercial reasons.
First Title ensures distribution arrangements for its products avoid or minimise the risk of negatively impacting the fair value of the product and to do so must be able to identify the remuneration associated with the distribution arrangements.
A key part of consideration on value is understanding the final price paid by the customer for the products manufactured. Therefore, First Title is keen to understand any distribution chains where additional fees may be charged to the customer which are not funded by the premium paid to First Title for the product as these costs could affect the fair value provided.
Additionally, First Title may ask for an explanation of the services provided through the distribution arrangements and confirmation that a distributor’s remuneration is consistent with their duty to comply with the customer’s best interests.
We have conducted and conduct continuous reviews of our products with regards to vulnerable customers to ensure our vulnerable customer approach and related processes deliver good customer outcomes.
For our fair value assessments please see the below.
First Title Insurance plc has a Product Approval Process which is reviewed/updated on a regular basis to reflect the needs of the business and the expectations of our key stakeholders.
The Financial Conduct Authority (FCA) requires us to provide appropriate information on our product approval process to distributors. Our product approval process applies to all new products, as well as to products that have been significantly changed. Significant changes of existing insurance products include, but are not limited to, a proposed change to the insurance coverage, standard pricing, exclusions, excesses, limits or conditions and any other significant change to the terms and conditions. In these circumstances, the review will also include consideration of the potential impact the changes may have on an existing or potential customer.
Our product approval process:
- Puts customers at the heart of the process
- Is fully compliant with all regulation and legislation
- Is simple and efficient
- Is commercially minded
- Is flexible and agile
- Identifies the target market
- Ensures products provide fair value
Where a distributor charges fees or commissions to the customer, the assessment must consider whether that adversely impacts the overall value received by the customer. For this reason, and in order to comply with our regulatory obligations, we require our distribution partners to provide information about any additional remuneration paid by the policyholder and to demonstrate how it supports fair value.
In the unlikely event of a product not offering fair value to customers, we will take all reasonable steps to remedy the issue and to put policy holders in the position they would have been in had the product offered fair value. We will continue to monitor and update the Fair Value Assessments (FVAs) to ensure the fair treatment of customers and to adhere to market standards.
Our product approval process details the methodology and type of metrics we consider when conducting our FVAs. Our products are reviewed at least annually.
If you have any questions regarding Product Governance, please contact us at: compliance@firsttitle.co.uk
Our Fair Value Assessments (FVAs) consider at least:
- The intended target market of the product
- The nature of the product including the benefits, their quality and any limitations
- The type and quality of services provided to customers
- The expected total price to be paid by the customer when buying or amending the product
- How the intended distribution arrangements support fair value
It also considers a range of indicators and metrics such as:
- Commission rate
- Loss ratio
- Claims frequency
- Claims repudiation rate
- Customer complaint ratio
We will share the outcome of our FVAs, in line with the FCA guidance, but will not be sharing the actual detail contained in the FVAs as these are confidential documents that we are unable to share for commercial reasons.
First Title ensures distribution arrangements for its products avoid or minimise the risk of negatively impacting the fair value of the product and to do so must be able to identify the remuneration associated with the distribution arrangements.
A key part of consideration on value is understanding the final price paid by the customer for the products manufactured. Therefore, First Title is keen to understand any distribution chains where additional fees may be charged to the customer which are not funded by the premium paid to First Title for the product as these costs could affect the fair value provided.
Additionally, First Title may ask for an explanation of the services provided through the distribution arrangements and confirmation that a distributor’s remuneration is consistent with their duty to comply with the customer’s best interests.
We have conducted and conduct continuous reviews of our products with regards to vulnerable customers to ensure our vulnerable customer approach and related processes deliver good customer outcomes.
For our fair value assessments please see the below.