Roles Can Create Project Constraints
I often work in regulated industries, and regulators are very specific about roles and responsibilities.
Under FCA rules (e.g., PROD 4), there is a concept of Manufacturer, Distributor and Co-Manufacturer, and each role has specific legal obligations that pertain to:
Limit flexibility in how products are developed or changed.
Require additional documentation, testing, and approvals before launch of an insurance product
Impose timelines for reviews and compliance checks.
Why does this matter to a project manager?
In industries such as these, organisations must simultaneously uphold their legal obligations and cannot stray into other territory by attempting to take on a role which they have not been designated. When working on strategic commercial transformation projects, such as a new insurance product launch, or a change of capacity provider, these roles and the tasks allocated to each of them will affect the timeline sequencing and create both constraints and dependencies within the plan.
Examples
A distributor cannot launch a campaign for a product until the manufacturer has completed target market testing and shared the required documentation.
If the manufacturer delays product testing, the distributor’s go-to-market plan is stalled.
A distributor may depend on the manufacturer for product specs, value assessments, and target market definitions.
Co-manufacturers may require joint governance structures or steering committees to manage shared responsibilities.
Therefore, taking a little time to understand these roles, and who within the project team (both internal and external parties) holds each of them, will not only deliver better clarity in the RACI matrix but most importantly, inform the proper sequence of events in the timeline, ultimately generating a more realistic view of time to deliver.
Manufacturer (PROD 4.2)
A Manufacturer is any firm that designs, creates, or significantly adapts insurance products.
KEY RESPONSIBILITIES:
Product Approval Process
Must maintain a documented process for approving new products or significant adaptations before marketing or distribution.
The process must be proportionate to the product’s complexity and risk.
Target Market Identification
Define a clearly identified target market for each product.
Ensure the product is designed to meet the needs, characteristics, and objectives of that market.
Product Testing
Conduct qualitative and quantitative testing to assess product value and suitability.
Consider potential harm if the product design is flawed, especially for wide target markets.
Ongoing Review
Regularly review products to ensure they remain appropriate and continue to offer fair value.
Monitor whether products are reaching the intended target market.
Information Sharing
Provide sufficient, reliable, and up-to-date information to distributors to enable proper distribution.
Distributor (PROD 4.3)
A Distributor is any firm that offers, recommends, or sells insurance products designed by a manufacturer.
KEY RESPONSIBILITIES:
Understand the Product
Must obtain adequate information from the manufacturer to understand the product and its target market
Distribution Strategy
Ensure the distribution strategy is aligned with the product’s target market.
Avoid selling products to customers outside the intended market.
Customer Outcomes
Act in the best interests of customers.
Ensure the product provides fair value and is not mis-sold.
Feedback to Manufacturer
Provide feedback on product performance, customer complaints, and any issues that arise during distribution.
Co-Manufacturer
A Co-Manufacturer is a firm that jointly designs or significantly influences the design of a product with another firm.
One firm (typically the insurer or managing agent) may be designated as the lead for compliance purposes.
KEY RESPONSIBILITIES:
Co-manufacturers are subject to all the same obligations as manufacturers under PROD 4.2.
Must work closely with the other co-manufacturer(s) to ensure the product meets regulatory standards and delivers fair value.