Product Governance – Broker Information Exchange
As of the 21st November 2021, the Financial Conduct Authority (FCA) published their updated Policy Statement setting out the rules of insurance pricing and enhancing product governance. This is designed to improve competition and ensure that general insurance offer fair value products to consumers.
Direct Commercial Ltd (DCL) are required by the FCA to demonstrate that we are actively reviewing our products to ensure they continue to be considered as fair. We are approaching our annual assessment and the collating of information in the form of a questionnaire. Your support is needed to ensure we are meeting the requirements set out by the FCA.
- We require your co-operation with our questionnaire to collect information regarding remuneration and additional services that exists throughout the entire distribution chain between DCL and the end consumer. An example of all distributers in a chain is below:
- In order to make this a fair review, we need to ensure we have your support in ensuring that everyone in the distribution chain between us and the consumer provides this information for each of our products, so we can demonstrate we have completed a fair value assessment. If you act as a Wholesale Broker for DCL products, we must ask you share this questionnaire with your sub-brokers to complete. If you act as both a Wholesale Broker and a Retail Broker for DCL, you only need to complete this questionnaire once as this is captured in the questions.
Please note: If you exit the question set before completion, it will not be saved and you will be required to start again.
- We will take appropriate action when reviewing any potential concerns that fair value is not being demonstrated.
- DCL are required to produce a Fair Value Assessment document by the 31 July 2026.
What you need you to do
- Complete the below questionnaire for ‘Brokers’ no later than 17 July 2026.
- Support your sub-brokers with the completion of the survey by 17 July 2026
Open here to complete the Product Governance & Fair Value Questionnaire.
Why can’t DCL contact all of our sub-brokers directly?
To ensure this is a fair review, we want to make sure the review information is only from sub-brokers that sell DCL policies.
Is this compulsory?
Obtaining this information is at the request of the FCA.
Can brokers complete the question set on behalf of the sub-brokers?
Yes, as long as it is completed accurately.
Why is the FCA number required?
This enables us to track our responses.
Can we request a copy of this information?
Following confirmation that the full distribution chain has been completed by all parties, it is possible for us to share this information with you subject to all distributors’ agreement to do so.
What is “appropriate action” where there are concerns ‘fair value’ is not being demonstrated?
In the event there are any concerns that fair value is not being demonstrated, DCL would undergo a review with the broker to ensure that this concern is addressed and where required, rectified.
Where can a copy of DCL Product Information Sheets be found?
The May 2026 Product Information Sheets will be shared to our brokers using REG and are also available on the ‘Reference’ section of our website.
Where can a copy of the Fair Value Assessment be found?
The July 2026 Fair Value Assessment will be shared to our brokers using REG and will also be available on the ‘Reference’ page of our website once they have been issued.
The July 2025 Fair Value Assessments can be found at the same location.
The link to the question set doesn’t work?
This link should be accessible to everyone and is not restricted by us. In the event you are unable to access the link, please first enquire with your IT team to investigate and if the matter cannot be resolved, then please contact our agency team.
What happens if this question set is not completed?
As this information review is at the request of the FCA, we will be tracking the response from all of our brokers and sub-brokers. Any firm that does not complete this will be recorded.
Can this information be submitted in an alternative form?
We would politely request that if possible, the question set is completed via the link we have shared.
Does the question set need to be completed for each DCL product?
There is only one questionnaire to be completed. You will be asked if you provide different fees and services across DCL products which you will then be asked to specify for each product where they differ.
What if the ‘minimum’ and ‘maximum’ charged are the same?
Please enter the same value for each of the questions.