Insurance Distribution and Product Governance Review

Ongoing review of insurance distribution and product governance requirements continues to focus on whether product design genuinely reflects target market needs, rather than target market analysis being conducted retrospectively to support products already designed.

This distinction matters more than it might initially appear: supervisors are increasingly testing the sequence of a firm's product development process, not just its documented outputs, looking for evidence that target market analysis genuinely shaped design decisions.

We're advising insurance clients to review their product development governance specifically for this sequencing question, since a target market analysis produced after a product's core design is fixed will struggle to evidence genuine influence over that design.

This briefing reflects Alden Advisory's general commentary on a developing regulatory topic and is not legal or regulatory advice. Firms should seek specific guidance for their own circumstances.