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  3. Point in time
    2015-06-03

COBS 13.2 Product information: production standards, form and contents

COBS 13.2.1GRP

1When a firm prepares documents or information in accordance with this chapter, the firm should consider the rules on providing product information (COBS 14). Those rules require a firm to provide the product information in a durable medium or via a website that meets the website conditions (if the website is not a durable medium).

[Note: article 29(4) of the MiFID implementing Directive]

COBS 13.2.1AGRP

3When a firm prepares documents or information for a life policy, personal pension or stakeholder pension in accordance with this chapter, the firm should:

  1. (1)

    consider the rules on communicating with clients (COBS 4). Those rules require a firm to ensure that a communication is fair, clear and not misleading. In particular, a firm should:

    1. (a)

      take into account its target market's understanding of financial services when preparing documents and information;

    2. (b)

      present information in a logical order;

    3. (c)

      use clear and descriptive headings, and where appropriate, cross references and sub-headings to aid navigation;

    4. (d)

      where possible, use plain language and avoid the use of jargon, unfamiliar or technical language;

    5. (e)

      if it is necessary to use jargon, unfamiliar or technical language, provide accompanying explanations in plain language;

    6. (f)

      use short sentences;

    7. (g)

      (if the key features illustration is separate from the key features document) clearly cross-reference between the two and avoid duplication where possible;

    8. (h)

      concentrate on key product information, cross reference to background information, detailed explanations and information about how to apply for the product; and

    9. (i)

      avoid duplication and unnecessary disclaimers;

  2. (2)

    taking into account the means of printing or display, consider whether the following can be used to improve the client's understanding of the product, in particular:

    1. (a)

      design devices such as side annotations, shading, colour, bulleted lists, tables and graphics; and

    2. (b)

      the type size, line width, line spacing, and use of white space.

COBS 13.2.2RRP

A key features document and a key features illustration 2must also:

  1. (1)

    (if it is a key features document) 2be produced and presented to at least the same quality and standard as the sales or marketing material used to promote the relevant product;

  2. (2)

    (if it is a key features document) 2display the firm's brand at least as prominently as any other;

  3. (3)

    (if it is a key features document or a key features illustration which does not form an integral part of the key features document) 2include the ‘Key facts’ logo in a prominent position at the top of the document; and

  4. (4)

    (if it is a key features document or a key features illustration which does not form an integral part of the key features document) 2include the following statement in a prominent position:

    “The Financial Conduct Authority is a financial services regulator. It requires us, [provider name], to give you this important information to help you to decide whether our [product name] is right for you. You should read this document carefully so that you understand what you are buying, and then keep it safe for future reference”.

COBS 13.2.3GRP

The Consolidated Life Directive information can be included in a key features document, a key features illustration 2or any other document.

COBS 13.2.4RRP

The documents and information prepared in accordance with the rules in this chapter must not include anything that might reasonably cause a retail client to be mistaken about the identity of the firm that produced, or will produce, the product.