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Target Market Statements (TMS)

The Financial Conduct Authority (‘FCA’) require product manufacturers to have product governance arrangements for the approval of each new insurance product and for when significant changes are made to existing products before they are marketed and distributed. They are also required to provide its distributors with an outline of the intended ‘Target Market’ for their products.

Freedom’s Product Oversight and Governance

Freedom Healthnet Ltd (‘Freedom’) has established a product governance process to oversee the design, approval and review of all our products in line with the requirements of the FCA’s Product Intervention and Product Governance Sourcebook (‘PROD’).

New product developments and changes to existing products are taken through a formal product approval process which is designed to:

  • Identify the target market and its needs;
  • tests customer understanding of the product;
  • consider the needs of any vulnerable customers; and
  • monitor post-sales performance.

Once a new or amended product is introduced to the market, Freedom will regularly review the product to see if any changes are needed and to make sure it remains suitable for customers in the identified target market.

If, as a distributor of Freedom products, you consider one of our products may be failing to meet customers’ needs or is potentially unclear you can help us by providing feedback through your usual point of contact at Freedom.

Target Market Statements

The FCA’s PROD rules require the product manufacturer to consider a number of points when designing products such as:

  • specify an identified target market;
  • identify relevant risks to the target market;
  • make sure the distribution strategy is appropriate for the target market; and
  • take reasonable steps to make sure the product is distributed to the target market.

The PROD rules also require the product manufacturer to share information about the intended target market for their products with their distributors. Freedom, the product manufacturer, has developed ‘Target Market Statements’ for each of its products to provide this information.

Our Target Market Statements are intended to clarify who our products are designed for, who they are not intended to support and how we expect the product to be offered to customers. They are aimed at advisers offering Freedom products to their clients and should not be shared with the client.

Selling outside the target market

The target market statement is intended to be a broad description of a general customer group and you should not assume a product is suitable simply because the customer is in scope and fits the broad description. A client may benefit from the product even if they are out of scope. It is the responsibility of the advisor to identify their client’s demands and to make a suitable recommendation in response.