Product Governance and Distribution

Financial Product Governance and Product Development

The Product Governance Regime has ‘gone live’ with the introduction of the Markets in Financial Instruments Directive Recast (MiFID II) from the 3rd of January 2018. The new regime is designed to ensure that when a firm manufactures or distributes regulated financial instruments, it has arrangements in place to understand the products and ensure they are only sold to investors and clients for which they are likely to be deemed suitable. The new requirements will apply to “services” as well as “products”, for all client types and to all distributors in the sales chain.


The  product governance requirements is to ensure that firms, which manufacture and distribute financial instruments and structured deposits, act in the clients’ best interests during all stages of the life-cycle or products or services.  This short course examines the organisational arrangements that firms will need to consider.


Session I:             The Overarching Product Governance Principles

The Product Governance regime has been introduced via the Markets in Financial Instruments Directive Recast (MiFID II) introduces a new regime to ensure that firm’s act in a client’s best interests, including funds and related management services, to end clients. The following session examines these proposed changes, including:

  • Clarify key regulatory principles that firms should review in relation to the product governance framework including governance; management oversight; roles & responsibilities; and process.
  • State the practical considerations for investor protection including target market; fair value; customer needs; and terms and processes.
  • Summarise the requirement to review products regularly to assess whether the product remains consistent with the needs of the target market of the product.


Session II:            Discussing Manufacturer Requirements

A manufacture is a firm which creates, issues and/or designs investments, including when advising corporate issuers on the launch of new investments. The following session examines regulatory changes for manufacturers and the impact on the market including:

  • State the new product approval obligation on firms acting as manufacturers
  • Presenting a model framework which promotes an appropriate approach to addressing conduct risk.
  • Describe the implication for relationships with third-country manufacturers, ensuring the level or product information meets the regulatory standard


Session III:          A Changing World for Distributors

A distributor is a firm which offers, recommends or sells investments or provides investment services to clients. This session examines the regulatory requirements including:

  • State new product approval obligations on firms acting as distributors
  • Summarise the impact for distributors in relation to suitability and appropriateness, information to clients, independent advice, inducements, and remuneration.
  • Analyse information to be presented by distributor’s to help in the manufacturer’s regular product reviews


Session IV:          Implementation Challenges

The product governance requirements has create new systems and controls to be put in place to design, approve, market and manage products throughout the product’s lifecycle to ensure that they meet legal and regulatory requirements. This session examines some of the challenges firms will face while implementing this new regime, including:

  • State implementation considerations for firm’s under the new regime including governance and management oversight, roles and responsibilities and monitoring.
  • Describe the new product intervention powers and consideration for complex and non-complex products.
  • Present lessons learnt from the UK implementation of its guidance in its Responsibilities of Providers and Distributors for the Fair Treatment of Customers (RPPD) Guide.
  • Identify future risks and regulatory considerations for firms post 3rd January 2018.

Workshop Style: 

This workshop is designed to be participative throughout. The agenda will combine key formal presentations, case studies and syndicate discussion sessions. There will be ample opportunity for delegates to benchmark experiences with industry peers and raise issues of most concern to their organisation, either confidentially or in open session.

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DATES: 12 February



LOCATION: CMS Training Centre, Limassol

TIME: 9:00 - 14:30

FEES: €220 + VAT


Who should attend:

Management, compliance and administration professionals whose companies are regulated by CySEC, particularly senior management, legal, compliance, internal audit and those employees at the coalface.

Registration Form

If you need help completing the online registration form, please give us a call at 2227 4470 or email us at 

In-House Training

The seminar is currently full and does not accept online registrations. If you want to be added to the waiting list please give us a call at 2227 4470 or email us at 

Trainer:  Vivienne Bannigan

Vivienne Bannigan is an independent regulatory risk professional with extensive experience in Wholesale Capital Markets in both the public and private banking sector in the UK and global markets. Vivienne advises senior management on regulatory policy changes, facilitating designing business strategy and frameworks to manage the regulatory and operational risk. In 2014 Vivienne had responsibility for facilitating the MiFID II consultation response on behalf of members at the British Banker’s Association (BBA). Vivienne started is passionate about coaching and empowering firms and individuals to be able to manage regulatory risk in a practical manner. Vivienne is a passionate sailor.