Context
The FCA has created a Consumer Duty information page, to provide firms with more information on areas of the Duty it has received queries from firms.
Key points to note
The main clarification points provided are:
- The FCA doesn’t expect firms to have necessarily fully scoped all work required to embed the Duty by the October deadline, but it does expect firms to have set out how they will do so in time to ensure timely implementation.
- The primary role of the Consumer Duty Champion is to support the firm’s Chair/CEO/MD in ensuring that i) the Duty is being raised regularly in all relevant discussions, and ii) the firm’s governing body/management is being challenged on how it is embedding the Duty and focusing on consumer outcomes. The Champion is not an executive role, and they are not responsible for the firm’s implementation of the Consumer Duty but for ensuring it is discussed at the Board.
- Closed products are defined as products that are no longer marketed or distributed to retail customers or open to renewal.
Next actions
None – for information and awareness.