Skip to content

Product Governance Case Study - Insurance Firm Consumer Duty Review

Product Review | Consumer Duty 

Our client is an international insurer that provides specialised risk solutions globally across a wide range of industries. The insurer's head office is in London.   


On the 1st of October 2021, The FCA introduced new rules (PS21/5) on Product Governance, Premium Finance and Reporting that apply to most insurance contracts (including retail, speciality and commercial).  These are referred to as “Fair Value” requirements.  

This regulation coincided with the more recently published PS22/9 - Consumer Principle, which came out on the 27th of July 2022 and requires firms to act to deliver good outcomes for retail customers. 

The Fair Value rules mandated an in-depth product review by 30th September 2022.  Insurers were required to identify all their products, the distributors of those products, the role played by those distributors, the prices charged, and commissions earned by the distributors, to determine whether the product offered fair value for the end customer.  

How FourthLine helped the client:  

Due to the volume of work and internal resource constraints, the client required Project Governance expertise, Project Management support and resource augmentation to complete the necessary product reviews by the September deadline.   

Each of the in-scope products required a formal interview with the lead Product Underwriter. For the interviews, FourthLine designed and implemented a client-specific questionnaire and an associated Fair Value Assessment (FVA) template containing the regulated requirements, which were approved by the client prior to implementation.   

Following the population of the FVA template, FourthLine ran workshops with the client’s Conduct Risk team to review the findings from a qualitative perspective and to agree on ratings for each of the Fair Value requirements.   

FourthLine then applied quantitative measures to the FVAs which were fed into an analysis tool.  The outputs from the analysis were used to identify trends and any areas of concern, which were used to inform the final report and associated action plan.  

The Outcome:  

All reviews and FVAs were completed, and a comprehensive report was produced to enable the client to meet the FCA’s deadline and to construct an Action Plan to address the areas of concern raised as part of this engagement. 

The framework and artefacts produced as part of this engagement will enable the client to run their fair Value Assessments on an annual basis. 


FourthLine continues to work with the client, who is now in a strong position to meet all the key milestones in relation to their consumer duty requirements, which are due to come into force in April 2023.  

How FourthLine can help:

FourthLine's specialist consultants can conduct a full fair value assessment (FVA) on your products and services.

FourthLine is working with a number of financial service firms to help them with different Risk and Resilience compliance and enablement projects through a mixture of end-to-end consulting, advisory and managed service offerings. 

Read our Strategy and Framework Technical Paper
October 6, 2022
Jakes de Kock
Jakes is FourthLine's Marketing Director. He specialises in omni-channel, tech-enabled inbound marketing strategies to drive business growth within the b2b sector.
Contact Us

Company Number: 6952875

VAT Number: 981375491

Privacy Policy

Complaints Procedure

Code of Conduct


Stay up to date with industry news, risk and resilience events and webinars.

Copyright © 2022, FourthLine. All Rights Reserved.