UK FCA Consumer Duty (Principle 12 and PRIN 2A) 2a3-closed-products: Manufacturers of closed products maintain a process to assess whether any aspect of the product breaches the cross-cutting obligations and whether it affects groups of customers differently

What does 2a3-closed-products require?

For a closed product (not marketed, distributed or open to renewal) the manufacturer must keep and regularly review a process to assess whether any aspect of the product means the firm is not meeting the cross-cutting obligations for existing customers, and whether the product lands differently on different customer groups, in particular the vulnerable customers within the target market. Appropriate action following a review does not require the firm to give up vested contractual rights (payments already due, rights to charge for services already provided) unless a breach of earlier rules is found, but it does require mitigating future harm.