EBA has reported on how industry has implemented its Product Oversight and Governance arrangements guidelines. It found a mix of good and bad practices. Some of its criticisms were that:
- often the manufacturer’s commercial interests and prudential concerns are given more attention than customers’ interests;
- manufacturers did not appear to take into account the variations of customer needs and impact that depend on the product and the stages of the POG process;
- most manufacturers did not seem to pay attention to which distribution channels may not be appropriate, and generally used all channels; and
- there is evidence of different understanding of what elements of the guidelines mean.