Absolute Value Publications

[Shameka Roessler]

Manyframeworks had clearly set out principles for how the firm would apply the concept of fair value both generally and across product lines. There was often direct read across between the principles and factors that will be assessed and our guidance in FG22/5.

Some frameworks suggested that firms planned to rely, at least partly, on high-level or unevidenced arguments that their business models or ethos are inherently fair value. This could be, for example, due to their perception of how competitive or valuable their product or service offering is. Firms will need to consider how they could provide evidence for this view, and how they allow for their own critical analysis of this position to ensure they deliver fair value for their customers.

A small number of firms had not given sufficient thought to the distinction between manufacturers and distributors in PRIN 2A.4, and the relevant requirements that apply. This is an important element of our rules. It allows firms to capture and assess the relevant costs and benefits of their products/services or role in the distribution chain to ensure they provide fair value to customers.

Most frameworks set out a reasonable view of how to assess the benefits consumers can expect to receive. These also provided a sufficiently broad view of the overall costs to the consumer, including fees and charges, any non-monetary costs, as well as any potential distribution costs to consumers.

Some fair value frameworks were oriented towards the individuals who would undertake product-level value assessments, for instance by guiding the reviewer or providing practical statements, questions or challenges to consider at different stages.

A handful of frameworks contained clear discussion about how to price products sold as a package or bundle and assess them for value. There was a clear consideration of where bundling does, or does not, provide value to consumers. For example, one firm noted that a bundle should not be priced higher than its constituent parts unless there is value to the consumer from the convenience of products being bundled together.

Where firms are required to gather input from other firms or to pass on information to other firms in the distribution chain, it was often clear how and when this would be done and how the firm would treat and consider any information received.

A few firms who were active across several markets had a single generalised template for assessing fair value. But it was not always clear how the template would apply to products with very different characteristics and which may serve different target markets. Firms who provide a wide range of products and services across different market sectors may need to consider further how they adapt their approach to assessing fair value across these different market sectors.

Some firms did not consider the types of non-financial costs and benefits that retail consumers may reasonably expect to pay or receive. FG22/5 states that benefits may include the quality of the product or service and level of consumer service. Non-financial costs might include factors such as the time and effort to make a decision about a product, such as amending or cancelling it.

However, some firms did not give much consideration to broader contextual factors or their impact on fair value. Some firms only considered whether the financial value customers received was positive, and not contextual factors such as a critical assessment of the fairness of their pricing structure. We encourage firms to consider where these simple approaches to fair value may overlook pockets of harm. This is especially the case for large firms or those with complex business models and offerings.

A number of firms set out how they plan to look at differential outcomes for customers and demonstrated a range of ways to segment customers. For example, they considered the value received by back-book customers, consumers using different channels, subsets of consumers paying disproportionately high margins given the benefits they receive or subsets of consumers at risk of paying higher fees and charges.

Some frameworks included tailored analysis of fair value for consumers with characteristics of vulnerability. For example, analysis of how the needs and objectives for vulnerable consumer groups were likely to differ and thus how costs and benefits would vary, and indicators to understand the characteristics of consumers in the target market.

Some firms considered product or service-level cross-subsidies, where some consumers pay higher prices or generate higher profit margins, and the factors to consider when reviewing whether these products or services offer fair value. Our price and value outcome rules do not require firms to charge all customers the same amount, or to make the same level of profit from all customers. One firm considered whether it is using the margin from a product to cross subsidise different groups of customers and the impact this could have on value for different groups. Another firm considered how product-level cross-subsidies may affect fair value and discussed the circumstances under which this could result in harm for some customers.

Some of the information presented in frameworks tended to rely on average outcomes rather than analysis to understand the full distribution of outcomes. Providing fair value to different groups of retail customers is a central theme of our rules.

Even where firms are undertaking analysis of consumers using segmented groups, group averages could disguise outliers or pockets of poor value. Where firms include segmentation analysis in their value assessments, they may consider whether that gives decision-makers enough understanding of the distribution of differential outcomes like prices and mark-ups to be able to identify and rectify any instances of unfair value.

Under the Consumer Duty, firms are required to monitor and review the outcomes that their customers receive, using appropriate information or data to do so. Firms must also take appropriate action where their review identifies that a product or service does not provide fair value.

A number of firms set out clear rectification processes, complete with named owners, that they must follow if they identify that a product no longer provides fair value. In some cases, these included triggers which may require a new assessment, such as movements in a certain data indicator, and allowed for discussion and challenge at an appropriate level of seniority.

A number of firms proposed points-based or red/amber/green-style approaches within their fair value frameworks. These appeared appropriate in many circumstances. However, firms may want to consider whether they are giving sufficient weight to critical analysis around the ratings, how thresholds between points/ratings are drawn and whether decision-makers have sufficiently detailed information to review and challenge the assessment of fair value.

Similarly, some firms presented evidence relevant to fair value, without being clear about its limitations, so it was not apparent how decision makers would be able to critically review this evidence when assessing fair value.

Where firms are using market-level benchmarks or information on comparators within their assessments, they should consider how they are delivering fair value for their customers in absolute rather than just relative terms. Relative comparisons can hide fair value issues that are prevalent within a wider market and are just one factor in the consideration of fair value.

The site is secure.

The ensures that you are connecting to the official website and that any information you provide is encrypted and transmitted securely.

The globalization of the information and the wide use of the English language in the scientific world impose a not avoidable comparison to the scientific Italian journals, but with value indicators that if accepted without criticism could humble the undeniable internal values. In fact such comparison is based certainly on the quality of the contents, but it has already as background parameter the language of publication if the aim is that of an adequate diffusion. The questions that rise from the analysis of the problem are essentially two: if there is still room nowadays for surgical scientific publications in Italian language and if it is correct to accept in a closed box the indicator of international comparison conditioned by the English language, with the consequence that the definite value judgement is entrusted to external opinions. Certainly the Italian journals of surgery must aim both to quality and to their diffusion for reaffirm and validate their cultural rights. The quality depends on the authors and on the surgical environment in which they operate, beyond the engagement of the scientific direction of the journal; the diffusion on the correct employment of the English language, at last of the abstracts, and on the general editorial strategy pointing to encourage and promote the widest coverage of critique. It remains but to bravely loose the knot represented from the proposal of a uncritical acceptance of the indicator of the IMPACT FACTOR with the consequent absolute judge of quality, that fatally depends from an egemonic Anglo-Saxon filter, not exempt from an unavoidable lobbystic imprint.

Not all programs are offered for completion at each campus or through Berkeley College Online. Please review the academic program pages ( ) for information on where each program is offered. Additionally, all students may be required to take some courses at another campus or online.

Provides a foundation in the graphic language used to represent interior spaces by using drafting techniques and the proper use of drafting materials and tools. Introduces AutoCAD as a drafting tool. Topics include floor plans, reflected ceiling plans, elevations, sections, perspectives, standard symbols, scale and line weight.

3a8082e126