Context
Nisha Arora, the FCAs Director of Cross Cutting Policy and Strategy, gave a speech on marking three months since the Duty came into force. The FCA stressed that the Duty is not something where firms can tick the Consumer Duty box on a to-do list and move on, rather something that needs to become part of “who you are as a firm, your culture, and how you do business”, from Board to front-line delivery, and from product design to communications and customer support. The FCA want to see firms learning and improving continuously. If firms have not looked in detail at their customers’ experience, and are not monitoring outcomes for customers, including different groups, an ongoing basis, the FCA will see this as an indication that firms have not got to grips with the Duty.
Key points to note
- The FCA want to see firms learning and improving continuously. If firms have not looked in detail at their customers’ experience, and are not monitoring outcomes for customers, including different groups, an ongoing basis, the FCA will see this as an indication that firms have not got to grips with the Duty.
- Firms will need to make sure, and be able to show the FCA, that they are delivering good consumer outcomes. This will include firms’ implementation plans, data and monitoring, internal assessments, and how firms are preparing for the closed products deadline of 31st July 2024.
- As set out in the FCA rules firms’ Boards, or equivalent governing bodies, must review and approve at least once a year an assessment of whether they are delivering good outcomes for their customers. The assessment should include the results of the monitoring on whether the firm’s products and services are delivering expected outcomes in line with the Duty, and to also include any evidence of poor outcomes. Before signing it off, firms’ Boards need to agree the actions required to address any identified risks or poor outcomes and agree whether any changes to the firm’s future business strategy are required.
- Over the coming months the FCA will continue work across all sectors to test firms’ implementation and embedding of the Duty, and will share good practice to support the industry.
Next actions
None – for information and awareness.