The deadline for Distributor firms is on the horizon. With just over 3 weeks to go, is your firm ready?
Last Friday the FCA emailed all firms to remind them of the deadline and reminded firms of resources available. When the Duty comes into force in one month’s time you will need to make sure, and be able to show the FCA, that you are acting to deliver good customer outcomes and protecting consumers from harm.
1. Remind yourselves of the Dear CEO letters in relation to your firm’s permissions
a. Investments – Here
b. Mortgages – Here
c. Protection and General Insurance – Here
d. Payment Firms - Here
e. Credit Brokers – Here
2. 10 key questions for firms to consider:
a. Are you satisfied your products and services are well designed to meet the needs of consumers in the target market, and perform as expected? What testing has been conducted?
b. Do your products or services have features that could risk harm for groups of customers with characteristics of vulnerability? If so, what changes to the design of your products and services are you making?
c. What action have you taken as a result of your fair value assessments, and how are you ensuring this action is effective in improving consumer outcomes?
d. What data, MI and other intelligence are you using to monitor the fair value of your products and services on an ongoing basis?
e. How are you testing the effectiveness of your communications? How are you acting on these results?
f. How do you adapt your communications to meet the needs of customers with characteristics of vulnerability, and how do you know these adaptions are effective?
g. What assessment have you made about whether your customer support is meeting the needs of customers with characteristics of vulnerability? What data, MI and customer feedback is being used to support this assessment?
h. How have you satisfied yourself that the quality and availability of any post-sale support you have is as good as your pre-sale support?
i. Do individuals throughout your firm – including those in control and support functions – understand their role and responsibility in delivering the Duty?
j. Have you identified the key risks to your ability to deliver good outcomes to customers and put appropriate mitigants in place?
These questions should help firms to reflect on their implementation of the Consumer Duty and identify gaps or areas for improvement. Firms can also expect to be asked questions like these in their interactions with the regulator.
3. Visit the FCA’s Consumer Duty homepage where you will find additional information about the Consumer Duty, on-demand webinars and podcasts, and the option to sign up for email updates
If you want to discuss this further, simply give us a call on 01242 807010
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