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1 December 2022

How are your preparations going for the introduction of Consumer Duty?

We’ve been asking this question a lot lately and we’ve had all kinds of replies, from “we’re working hard on it” to “we don’t need to do anything.”

It’s unlikely there are any FCA-registered firms that don’t need to take action to ensure compliance with Consumer Duty. It is one of the biggest regulatory changes we’ve seen in a long time and the clock is ticking towards its introduction.

Assessing your actions

By now, you should have written and signed off your implementation plan, however, this is only the start of the process. So, what’s next?

We are finding some clients have already completed a review of their business, whereas others are not too sure how to drive their Consumer Duty preparation forward. Our recommendation is to undertake a benchmarking exercise, so you can identify where you are in relation to the FCA guidance and check if you have the necessary evidence within your current processes and controls.

We can help firms complete their benchmarking from scratch, or if you have already started the process, we can undertake a full health check on your preparations. For those clients who would prefer to go it alone, we are also providing access to a free DIY toolkit in SharePoint.

If you choose to carry out the full benchmarking exercise or health check, we will provide a detailed report, rating your current controls as red, amber or green against the Consumer Duty outcomes. It will include a list of issues identified and recommended improvements.

Testing and training

Regardless of where you are in the implementation process, all firms will need to provide some training on the new regulations.

Your team must understand the importance of gathering feedback and giving clients the ability to escalate issues. Changes to the SMCR and training and competency regimes will also need addressing.

As we discussed in our recent blog, client feedback is a key element of Consumer Duty. A lot of firms are already garnering opinion on their services, but now need to start evidencing that it is taking place and testing their processes against the regulations. We know not all of you are failing at this, but many do not record their actions.

Hands-on support

The aim of our benchmarking exercise is to encourage participants to question what you are doing to prepare for Consumer Duty and why, rather than just providing clients with an arbitrary list of action points.

Consumer Duty is here to stay and the actions you take to prepare for the legislation will probably have to be undertaken annually, for as long as you are in business. If anything, it will only get bigger. The FCA is waiting to see how firms adapt to the changes and whether they drive improved outcomes for consumers before implementing additional legislation.

Let’s face it, if we achieve better services for clients, that can’t be a bad thing.

If you would like more information about our Consumer Duty benchmarking exercise, don’t hesitate to contact us on (0161) 521 8641 or email:

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