Context
In line with other moves following the Chancellor’s Mansion House speech (the MoU between FOS and the FCA, the Call for Input to modernise the redress system) the FCA has published:
- an updated Terms of Reference for the Wider Implications Framework (acknowledging the closer working between FOS and the FCA as set out in the MOU);
- the latest version of the updated Wider Implications Framework log;
- the minutes of the Wider Implications Framework meeting held on 25 April 2024, and has updated its web page with the details of the updated ToR accordingly.
Key points to note and next actions
The log of live issues includes commentary on:
- developments post-Consumer Duty, including working together to ensure timely discussions take place at a sector level between FCA and FOS about key issues to support consistency in understanding and interpretation of new complaints, and continuing to look for opportunities for joint external events, for example roundtables with industry, with a focus on continuing alignment on how the Duty applies; and
- issues relating to undisclosed commissions, “…particularly in the motor finance sector…” (note, ‘particularly’, not ‘solely’), with the aim of ensuring a consistent and complementary approach to the interpretation of rules, guidance, legislation and relevant law related to commission complaints.
The meeting minutes outline a particular action to consider further the impact of the Consumer Duty on the other organisations, with a meeting between FCA and the Pensions Regulator (TPR) to be arranged.