Product Oversight & Governance

We wish to ensure that the products that we distribute provide fair value and support our commitment to high reputational and conduct risk standards, whilst adhering to legal and regulatory requirements. As a result of the new FCA Pricing Practices rules, we have updated our Product Oversight and Governance process and would like to share an overview of what we are doing in Touchstone Underwriting.

Why do we need to tell you about this?
Both the Insurance Distribution Directive (IDD) and the new Pricing Practices rules require insurers to maintain, operate and review a Product Approval Process and make appropriate information, including the identified Target Market for products, available to its distributors. Our revised process also considers information to evidence Fair Value to the customer for each product.

What controls does Touchstone Underwriting have in place?
Touchstone Underwriting has well-established product governance processes in place to oversee the design, approval and review of all our products which meet the requirements of the IDD, and the new Pricing Practices rules:

• New product developments and changes to existing products are subject to a formal product approval process
  Customer type, distribution channels, product marketing, monitoring of sales and post-sales performance as well as the wider market and legal developments are identified and considered as part of the product approval process
• We conduct a review of pricing structures to ensure that the product provides fair value to the customer in relation to the target market and the purpose for which it is intended.
• We ensure that, where relevant, we have sufficient information and training from insurers to enable us to provide the appropriate support.
• We conduct a staff training and competency review to ensure our staff who are involved in designing and manufacturing products have the skills, knowledge and expertise to carry out their roles in a way that meets the needs of our customers and our business
• Product lifecycle management – Our products are designed to meet specified needs of defined customer groups and reviewed to ensure that they perform and continue to perform as intended.

We also regularly check all of our products via a Customer Conduct Review to identify if any changes are required and to ensure that they remain suitable for our customers.

As a product manufacturer, Touchstone Underwriting will continue to monitor the performance of our products to ensure that they deliver the covers required and meet the needs of our customers. We welcome feedback from our brokers should our products be viewed as not meeting customers’ needs.

Fair Value Assessments

We do not pay enhanced commissions on our products.

We internally review data which can signal any product no-performance, this includes, Loss Ratio,  NTU / Cancellation rates and/or Complaints.  There are no trends on any of our products. We have a very low NTU and Complaint Ratio which is, we feel a testament to the quality of the product we provide.

• We do not charge fees,
• We do not have “Add Ons”
• There are no Auto-Renewals.
• Our pricings do not differentiate between whether the risk is New Business or Renewal.
• On the incredibly rare occasion that we assist with Finance arrangements, we do so at the minimum terms available from the suppliers with no charges added.
• IPID/ Cover summaries and Full policy wordings accompany every Quotation and Renewal and further documents can be obtained in our Product Library

Broker Regulatory Obligations

Our brokers must continue to meet all relevant regulatory obligations, and specifically, that:

• a distribution assessment has been completed for all products in line with PROD 4.3.10 including any impact remuneration has on fair value;
• remuneration you receive does not conflict with your duty to comply with the customer’s best interest rule.
• remuneration is consistent with general regulatory obligations (including SYSC 19F.2) and fair value requirements (PROD 4.3.6A);
• remuneration is disclosed in accordance with ICOBs 4.3;
• remuneration received bears a reasonable relationship to the Services provided to the customer; and
• you operate an appropriate conflicts of interest control framework (SYSC 10.1).

Brokers must sell our product(s) in accordance with Touchstone Underwriting Target Market Statement(s), details of which can be found below.

If you have any queries or need assistance, please contact chris.harris@t-u-l.co.uk.

Products