The FCA has published or updated three web pages in relation to the Consumer Duty, one of which is a reminder for firms about what they should be doing and considering with one month to go to the Consumer Duty implementation date. The FCA’s Consumer Duty ‘home page’ has been updated, and includes a link to the results of the FCA’s Spring 2023 small firms Consumer Duty survey.
The ‘One month to go’ web page includes a set of ten questions that the FCA encourages firms to consider, and which references the Consumer Duty Finalised Guidance as another source of questions for firms to consider. The FCA also explains that 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 any interactions with the FCA.
The ten questions are:
- 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?
- 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?
- 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?
- What data, MI and other intelligence are you using to monitor the fair value of your products and services on an ongoing basis?
- How are you testing the effectiveness of your communications? How are you acting on these results?
- 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?
- 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?
- 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?
- Do individuals throughout your firm – including those in control and support functions – understand their role and responsibility in delivering the Duty?
- Have you identified the key risks to your ability to deliver good outcomes to customers and put appropriate mitigations in place?
We recommend that firms review the published / updated web pages to understand the FCA’s direction of thought in relation to Consumer Duty implementation and readiness.