Funeral plan providers

We have a dedicated team of specialists who have previous experience in advising funeral plan providers of all sizes, from those which are vertically integrated, those that offer plans abroad, all the way through to more simplistic and traditional funeral plan offerings. Our experience includes advising funeral plan providers who are both trust and insurance backed.

Whether it’s reviewing your approach to product governance, sales, redemption, conducting periodic compliance reviews, or offering expert advice on how to improve policies and procedures, our team of specialists can help.

Our team of regulatory specialists includes subject matter experts with a mixture of industry and regulator experience. This allows us to be pragmatic and tailor what the right approach is for each client we work with, taking into account the nature, scale and complexity of your firm.

Our support can be agile and tailored to your needs with as little or as much support as you want. Our services include, but are not limited to:

Periodic reviews

Whether as part of your compliance monitoring or internal audit programme, we can support you with independent assurance on the design and operational effectiveness of your approach. This could be in relation to anything from product design and pricing, sales, all the way through to the handling of funeral plan redemption.

Staff training

We can conduct tailored complaints training, which focuses on the FCA’s expectations. Alternatively, we can review your training material to verify if this is sufficient and catered appropriately to staff at differing levels of seniority. We can also review whether your route to competency framework is effective by design, but also operationally effective.

Product governance

We can review your firm’s approach to product governance, including but not limited to reviewing your product governance framework (policy/procedures), target market assessments, design effectiveness of customer documentation, product performance MI metrics and thresholds (including whether this is of sufficient granularity), reporting and governance and product assessments.

Appointed Representatives/Introducer Appointed Representatives

We specialise in reviewing the design effectiveness assessments of AR frameworks, including a review of policies, procedures and supporting documentation which supports both of these. We can provide you with our view on whether your AR framework meets the FCA’s expectations. Additionally, we can conduct operational effectiveness testing of your approach to AR/IARs, including but not limited to onboarding processes, ongoing oversight/continuing obligations as a Principal firm, as well as termination (where applicable).

Sales

We can conduct a review of your full sales journey, or any one particular part of your sales journey. This includes but is not limited to customer engagement with marketing/financial promotions, website sales journeys, telephony sales journeys for new customer sales, the sale of add-on products, mid-term adjustments for existing plan holders, and cancellations where applicable.

Solvency/actuarial

We can review whether you are meeting the FCA’s expectations regarding capital, liquidity and trust solvency, including but not limited to reviewing your approach to completion of solvency assessment reports.

Redemptions

We can review your firms approach to redemption handling, including but not limited to reviewing calls, management information and governance, quality and timely provision of the agreed funeral within the plan, and ultimately whether good outcomes were provided.

Complaints

We offer a variety of complaints services. Please refer to our complaints webpage which can be located here.

Authorisations

We can assist you with obtaining regulatory licences/permissions from the FCA, whether you’re an already established firm looking to expand, or a start-up business. Please refer to our authorisation’s webpage for more information.

Our experience

A member of our team continues to support the National Association of Funeral Plan Providers (NAFPP) with their sector consultation of reviewing FPCOB with its members. They continue to assist the NAFPP with drafting a consultation paper for the Association to communicate with the FCA.

Recently, we have supported a large funeral plan provider with reviewing its approach to marketing versus the FCA’s expectations surrounding the payment of commissions under FPCOB 6.4 and FPCOB 6.5.

Additionally, we have recently supported funeral plan providers with the following:

• Creating Appointed Representative frameworks;
• Managing Voluntary Requirement (VREQ) Notices from the FCA;
• Design, creation and implementation of product governance frameworks;
• Consumer Duty implementation; and
• SMF16 readiness assessments and mock interviews for SMF applications.