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Chapter 9 - Guidelines - Structured Deposits, Switching, Fair Dealing ,…
Chapter 9 - Guidelines - Structured Deposits, Switching, Fair Dealing , Balanced Scorecard Framework,Reference Checks And Pre-Transaction Checks
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9B: switching products
Switching recommendation: 1. “Know Your Client”, needs analysis, and documentation and record-keeping 2. disclose fee & charges
Monitoring of switching: front-end - client to declare in writing, back-end- Company (putting in place procedures to ensure that each switch recommended by a representative is reviewed by a supervisor for appropriateness)
9C Fair Dealing
Five Outcomes
- Customer Confidence (How FI operates affect customers' financial decisions
The board and senior management responsible, how to
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product Due Diligence: 1. A financial institution Fully understand and evaluate the features and characteristics of the product, and assess the implications on each customer segment ; 2. identify customer segments for which the product is suitable, and customer segments for which the product is clearly not suitable.
Review point-of-sale documents: Services & charges, T&C, marketing material, prospectus, pricing statement, fact sheet, ...
Before allowing a product or service to be marketed to customers, a financial institution should provide training for its representatives on the relevant features and risk-reward characteristics. I
It should also clearly communicate to its representatives the customer segments that the product or service is suitable for, and to take extra care and attention with vulnerable customers.
The financial institution should educate its representatives to consider how a product may or may not be suitable for a customer, given his profile and overall portfolio.
The financial institution should educate its representatives to consider how a product may or may not be suitable for a customer, given his profile and overall portfolio.
To underscore the importance of supervisory oversight, the financial institution should ensure that supervisors are primarily focused on performing supervisory duties and are not distracted by their own sales responsibilities.
- Clear, relevant, timely information
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- complains handled in independent, effective, and prompt manner
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