The FCA have released their final Consumer Duty rules. This is where the work begins! We have been discussing with firms assessing possible areas of their business that could be impacted by Consumer Duty. Now that we know the final rules, we can support you with the implementation and changes required.
The purpose of this document is to help you break down the rules in order to consider each section individually. This will then aid you in your understanding of how each should be implemented into your business and which areas are likely to have the greatest impact.
There are three ‘cross-cutting’ rules, which address how businesses should conduct themselves in order to ensure they are delivering the correct outcomes for their clients.
- Act in good faith.
- Take all reasonable steps to avoid causing foreseeable harm to consumers.
- Take all reasonable steps to enable consumers to pursue their financial objectives.
The FCA explicitly states that each of these is essential to the level of care firms should provide
to consumers, so all need to be taken into account.
In terms of the ‘outcomes’ these relate to:
- Product and services – providers must be clear about their target market, and any risks posed by their products, and also be clear on product information. Distributors must do the same and take steps to prevent the wrong consumer types from buying/receiving those products.
- Price and value – firms need to consider the impact of charges or price over the lifetime of the product or service and check that the benefits to the consumer are proportionate. This does not mean the imposition of price caps though. In essence, here we are suggesting that firms are clear about whether there is added value by the firm being involved in the distribution of this product or service.
- Consumer understanding – firms should communicate in a way that is reasonably likely to be understood, facilitate decision making and take proportionate steps to review and adapt communications to adhere to the above.
- Consumer support – customer services must not unduly hinder consumers from acting in their own interests or lead to unreasonable additional costs for consumers, including time costs.
The vast majority of firms will have some work to do to satisfy the Consumer Duty all firms need to start drafting their implementation plans and start to gather or create the evidence required to ensure it is deliverable and robust.
HOW PEAK CAN HELP!
We are providing a service where our subject matter experts can provide an impartial, detailed health check initially and can then assist you in a fully independent implementation project after the findings, or just supply help as and when you need it.
What’s more, we are well versed in implementation planning, delivery, and oversight, providing you with everything you need to get ahead of the curve with everything ‘Consumer Duty’. Please get in touch with one of our experts to discuss further.