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Link(s):Happy 2nd Anniversary Consumer Duty! | LinkedIn
(1) From Reflection to action: The Consumer Duty’s impact on insurance | LinkedIn
(1) Consumer Duty at two: Progress, partnership, and the path ahead | LinkedIn
Two years on: how the Consumer Duty is putting pounds back in pockets | LinkedIn
(1) Two years of the Consumer Duty – rising to the challenge | LinkedIn

Context

The FCA has issued its latest Consumer Duty update e-mail, reflecting on the second anniversary of the implementation of the Duty and also including commentary of its recent work on digital design in customers’ online journeys.  The e-mail also comments on the Regulatory Summit that the FCA hosted in London in July, to explore how the FCA can further simplify its rulebook (the FCA will provide an update in September on the next steps of this work).

Key points to note and next actions

  • The update e-mail highlighted five blogs that the FCA had published on LinkedIn, unannounced, between 29th July and 2nd August, including commentary on retail banking, consumer investments and consumer finance.
  • In his insurance-related blog prior to leaving the FCA, Matt Brewis commented on improved partnerships and better outcomes, and seeing plenty of good practice from firms.  He also commented on acting on harm where it is identified, and what lies ahead:
    • looking at the international scope of conduct rules;
    • simplifying rules for insurance and funeral plans;
    • reviewing insurance pricing reporting requirements; and
    • reviewing and potentially removing detailed and prescriptive product-specific rules, including those for packaged bank accounts and GAP insurance.
  • Charlotte Clark, commenting as Director of cross-cutting policy at the FCA, discussed the Duty helping to make a real difference to financial lives. Clark comments on the Duty being good for consumers, for business and for growth, and sets out her views on ‘where next’ for the Duty:
    • It is central to the FCA’s 2030 strategy vision.
    • it remains a mindset shift; one that aligns long-term business success with doing the right thing for customers.
    • The message is that the FCA is ‘here to help’, and that it is listening.
    • The FCA is focussed on sharing good practice and supporting firms to deliver good outcomes under the price and value outcome, and will continue with its ambitious programme of action to use the Duty to future proof and streamline its rules.
Link(s):Almost 5,000 fake FCA scams reported in first 6 months of 2025 | FCA

Context

The FCA has issued a press release warning consumers of fraudsters impersonating the FCA, revealing it received almost 5,000 fake FCA scam reports in the first half of 2025.

Key points to note and next actions

  • There have been 4,465 reports of fake FCA scams to the regulator’s consumer helpline already this year. 480 victims were duped into sending money to the fraudster.
  • The majority, almost two-thirds, of reports came from people 56 years old or above.
  • One of the most common scam methods reported is fraudsters claiming that the FCA has recovered funds from a crypto wallet that was opened illegally in the individual’s name.
  • Another common method is to target loan scam victims, who are often very vulnerable, and claim the FCA can help them recover the money they have lost. They are then persuaded to hand over further funds.
  • A separate trend involves emailing consumers telling them their creditors have taken out a County Court Judgement against them and they need to pay the FCA the monies owed.
  • The press release includes tips to avoid fake FCA scams.
Link(s):Organisations must prepare now for new fraud prevention law | The Crown Prosecution Service
Corporate Prosecutions | The Crown Prosecution Service
New failure to prevent fraud guidance published  – GOV.UK
Guidance to organisations on the offence of failure to prevent fraud

Context

In November 2024 the Home Office published a 46-page Guidance Note on the new corporate offence of failure to prevent fraud, which was introduced under the Economic Crime and Corporate Transparency Act 2023.  This new fraud prevention law comes into force on 1st September 2025.  The CPS has published a reminder about preparing for the incoming law, as it has, in conjunction with the Serious Fraud Office (SFO), also published joint updated guidance for prosecutors around dealing with corporate prosecutions.  In essence, the offence is to fail to prevent fraud committed by an employee or agent for the organisation’s benefit.

Key points to note and next actions

  • The new “failure to prevent fraud” offence will make large organisations legally responsible for preventing fraud committed by their employees and other associated persons.
  • ‘Large organisations’ are those  defined as those meeting at least two of the following criteria:
    • More than 250 employees
    • Annual turnover exceeding £36 million
    • Balance sheet total exceeding £18 million
  • Although many of our clients will not meet two of these three criteria, it may be useful for insurance brokers dealing with larger corporate clients to remind those clients to be aware of the new risks that this new law will bring.
  • A defence is available in relation to the new offence by demonstrating that an organisation had reasonable fraud prevention procedures in place, or that it was not reasonable in the circumstances to expect the organisation to have any prevention procedures in place.
Link(s):LMA – Updated Excess Health Care Liability Policies Published by the LMA Medical Malpractice Committee
Summary-of-Changes-to-LMA3172-LMA3173.pdf

Context

The LMA’s Medical Malpractice Committee has produced an updated Excess Health Care Provider’s Liability Policy wording, for use on US risks.  wo variants of the updated wording will be published, the main difference being alternative Claims Co-operation language.

Key points to note and next actions

  • The previous versions of the policy (LMA3172 and LMA3173) will be archived on the Lloyd’s Wordings Repository (LWR).
  • An Occurrence – General Liability Endorsement has been released for use with the updated wording.
  • The endorsement amends the insuring agreement under the General Liabilities section of the policy to apply on an occurrence basis.
  • A document summarising the main changes to the wording has also been produced.