Robust, proactive reviews are central to protecting consumers and lifting overall conduct standards, insists executive
The Financial Markets Authority (FMA) has released a thematic review outlining how financial institutions are reviewing their products and services, and where they need to improve.
The report follows a year in which the FMA has sharpened its outcomes‑focused, intelligence‑led approach to regulation – as highlighted in its 2025 Annual Report, which also reported higher engagement from industry in the latest Ease of Doing Business survey
In a media release, Clare Bolingford (pictured), executive director, licensing, and conduct supervision, said robust, proactive reviews are central to protecting consumers and lifting overall conduct standards.
“When financial institutions proactively review products and services, they can identify and respond to consumer harms, and help promote improvements in the provision of financial services that meet the needs of consumers," Bolingford said.
"This supports some of the key outcomes we want to see for consumers and financial markets, including fair services, quality ongoing service, and well-informed consumers.
“Institutions such as insurers and deposit takers should treat this report as a guide for continuous improvement. But it does not create new legal obligations.
“As part of our normal supervisory activity, financial institutions can expect proactive reviews of existing products and services to be a continued area of interest for the FMA."
Consumer needs, vulnerability, and governance in focus
The report sets out the key features FMA expects to see in effective product and service review frameworks, starting with a strong consumer lens.
“Companies should ensure consumer requirements and objectives are central when they design and carry out reviews, and should adopt a risk-based and flexible review schedule that can respond to internal and external factors,' Bolingford said.
“They should also incorporate consumer vulnerability considerations and ensure products and services remain accessible and fair.
“Strengthening governance and board reporting to ensure accountability and oversight is key, as is improving consumer communication strategies to build trust and transparency.
“And finally, companies should ensure they have established clear processes for tracking and implementing review outcomes, including post-review monitoring.”
The FMA leader said the regulator was pleased all 20 participating institutions confirmed they conduct reviews, with approaches varying according to size and complexity. Firms are encouraged to learn from good-practice examples set out in the report.
“Communication with consumers about review outcomes is inconsistent; some firms have mature strategies although some lack clarity on when and how to inform consumers," Bolingford said.
“Action tracking from reviews is a developing area, with good practice involving structured follow-up, ownership, and effectiveness monitoring."
Off-sale products, legacy systems, and complaints handling flagged as weak spots
The thematic review also highlights several areas where firms need to lift performance, including their treatment of off-sale and legacy products, systems risk, and the use of complaints data.
“For example, off-sale and legacy products and services were often reviewed less frequently than on-sale products and services," Bolingford said. "Risks may be heightened where consumers interact with the product or service less frequently, as it is less likely issues will be surfaced by consumers.
"The FMA’s fair dealing enforcement activity has often related to off-sale or legacy products. Conducting regularly scheduled reviews may help prevent the types of issues that lead to consumer harm and potential enforcement action.
She also pointed to long‑standing technology and process issues in banking and insurance.
“As noted in our Financial Conduct Report, conduct risks in the deposit taking and insurance sectors remain high from reliance on legacy technology, systems, and manual controls and processes, as well as inadequate staff training," Bolingford said. "Failures in systems and technology have led to consumer harm in the past.”
She said many firms are also still under‑using complaints and dispute resolution schemes as a source of insight.
“As noted in our complaints info sheet, complaints can offer important insights into what is and isn’t working well,” Bolingford said.
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