Case Study: Translating CCI Policy into a Clearer Product Summary Experience

An asset management client approached FundSense with a practical question.

How should the FCA’s Consumer Composite Investments (CCI) Policy Statement be interpreted in the design of a CCI Product Summary Document?

Like many firms preparing for CCI, the client had reached the point where regulatory understanding needed to become a practical document design. The challenge was no longer identifying the requirements. It was deciding how those requirements could be presented in a way that genuinely helped a retail investor understand the product.

FundSense treated the proof of concept as a practical translation exercise, working with the client and Investment Solutions Consultants (ISC) to explore how regulatory intent could be translated into an effective investor-facing document.

The challenge

CCI implementation creates a familiar challenge for asset managers.

Regulation sets the direction, but firms still have to make practical decisions about structure, hierarchy, tone, data, ownership and production.

A Product Summary Document needs to be accurate, complete and aligned with the rules. It also needs to work for the person reading it.

A retail investor should be able to form an initial view of the product, understand the key information, see where more detail sits and move through the document without unnecessary friction.

For the client, the question was how to bring those needs together in a document that supported investor decision-making while remaining controlled, repeatable and aligned with the regulatory purpose.

Developing the proof of concept

FundSense led the development of the proof of concept, coordinating the overall document design approach while working closely with the client and drawing on specialist front-layer design expertise from ISC.

The work began by combining ISC’s thinking around investor-oriented front-layer design with FundSense’s focus on operational delivery, governance and document production.

From there, the team moved through iterations of drafting, tone and balance. Each refinement tested whether the document was becoming clearer, more coherent and more useful from the investor’s point of view.

As the concept matured, the focus began to shift. The remaining questions were no longer only about wording. They were about how the document would work as an experience.

• Would the hierarchy be clear?

• Would the opening layer carry enough context without becoming too dense?

• Would the reader know where to go next?

• Would the document work for investors while remaining a controlled regulatory output?

This moved the proof of concept into a more practical phase. It was no longer just about whether the right information had been included. It was about whether the information had been organised in a way that could support understanding, usability and future production.

What the proof of concept showed

The proof of concept gave the client a practical way to explore how CCI requirements could be interpreted and applied, combining regulatory interpretation, investor communication principles and practical implementation considerations.

It showed that Product Summary Document design needs to bring together several disciplines at once: regulatory interpretation, investor understanding, product data, document production, governance and change control.

It also highlighted a broader implementation point.

CCI is a coherence challenge.

The document may be the visible output, but the quality of that output depends on the operating model behind it. Product, compliance, marketing, operations and distribution all have a role to play. The data needs to be traceable. Documents and machine-readable outputs need to stay aligned. Distributor use needs to be considered. Future changes need to be managed without losing control.

A clear concept is only useful if it can become a reliable production process.

Where FundSense adds value

FundSense helped turn the client’s regulatory interpretation challenge into a practical document design exercise.

By bringing together regulatory interpretation, investor communication principles and product considerations, FundSense helped the client develop an approach that could be tested, reviewed, and refined in practice.

The proof of concept showed how FundSense can help asset managers move from understanding regulatory change to implementing it in a controlled and usable way.

That means thinking beyond the document as a standalone output. It means considering how the document is structured, how the underlying data is governed, how review and approval work, how changes are managed and how the final output supports the investor’s decision.

The project also demonstrated the value of bringing together complementary expertise, combining investor communication design with operational implementation and governance thinking.

Supporting firms with CCI document design

FundSense helps asset managers translate regulatory requirements into controlled, practical document and data workflows.

For CCI, that includes Product Summary Document design, investor decision support, governance, production and change management.

As firms move from interpreting the CCI requirements to implementing them, the challenge will be turning regulatory intent into a practical, repeatable investor experience. To discuss CCI Product Summary Document design, investor decision support or a practical CCI workshop, contact FundSense to arrange a discussion or demonstration.