What happened?
In an article published in Insurance Edge, TCC Group CEO Joe Norburn explores the FCA’s pure protection distribution market study. The regulator is thoroughly investigating fair value, broker commission structures, competition, and consumer access to protection products.
With the study’s final report due in Q3 2026, firms are advised to proactively audit their policies and strengthen their evidence trail.
Why does it matter?
Firms cannot afford to wait until the final report is published. Remuneration models and distribution channels must be reviewed to ensure they do not cause consumer harm or create conflicts of interest, allowing firms to demonstrate clear alignment with Consumer Duty standards.
Supporting sources
Frequently asked questions
How should firms prepare for the pure protection study outcomes?
Firms should strengthen their internal governance, review broker commission models, and improve transparency around pricing and fees to ensure fair value is evidenced across all customer groups.
What is the FCA's primary concern in pure protection?
The FCA is concerned with commission-driven incentives and complex distribution models that may lead to higher costs, limited product access, and poor value for consumers.
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- BankingTCC helps retail banks, challenger banks, building societies and specialist banking providers strengthen governance, manage financial crime risk and demonstrate good customer outcomes. Our specialists support Consumer Duty, remediation, regulatory transformation, FCA intervention and compliance assurance programmes through advisory, managed services, specialist resourcing and technology-enabled compliance. With more than 25 years of experience supporting FCA-regulated firms, we help banks respond confidently to regulatory scrutiny while strengthening operational resilience and customer trust.
- General Insurance & ProtectionTCC helps insurers, brokers, MGAs and protection providers evidence fair value, strengthen customer outcomes and identify emerging customer harm. We assess product governance, claims performance, distribution oversight and vulnerability risks, helping firms create regulator-ready evidence, improve operational performance and demonstrate that products and services deliver value throughout the customer lifecycle.
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