Context
The FCA has published a blog by Charlotte Clark, FCA Director of Cross-Cutting Policy and Strategy, outlining the FCA’s expectations of firms in supporting customers in challenging times, , through the Consumer Duty and its rules on protections for borrowers in difficulty.
Key points to note and next actions
- The FCA expects firms to have embedded the Duty and to monitor outcomes actively, identifying where consumers are at risk of harm in a rapidly changing environment.
- In relation to products and services, firms must check that products and services still meet the needs, characteristics and objectives of their target market as circumstances change.
- In relation to price and value, firms must regularly review whether customers still receive fair value as circumstances change. Firms should keep monitoring outcomes for higher-risk customer groups and act if they find that a product no longer offers fair value.
- In relation to consumer understanding, customers may need clearer, more timely and more prominent information to make effective decisions. Some may be experiencing payment difficulties for the first time and may not know what support is available. Firms should test communications (including digital journeys and scripts) to make sure customers understand key terms, the consequences of inaction and the support available.
- In relation to consumer support, the Duty requires firms to keep support accessible and effective as customers’ needs change.
- The FCA will continue to engage with firms to deliver good outcomes for customers, and urges firms to keep in mind that, for those customers who hold multiple products with the same firm, firms may need to adopt a holistic view across those products to make sure they are delivering good outcomes.
In summary, firms should:
- check that their current approach remains appropriate in the current environment and make changes where it does not; and
- take timely action and retain clear evidence of the impact on customer outcomes where firms identify that foreseeable harm may be caused.
