Recommendation 140

The London Market Group noted that Fair Value Assessments apply a similar burden. These are a component of the wider Consumer Duty regulation and require firms to demonstrate that the price consumers pay for products and services is reasonable compared to the benefits they provide. 211 The London Market Group provided the example of a UK-headquartered insurance broker in which “8 of these UK staff are responsible solely for completing Fair Value Assessments, the majority of which are in respect of products provided to corporate clients, not retail customers.” 212 These burdens impose direct staffing costs and may have resultant opportunity costs to firms required to produce these documents unnecessarily.