The FCA has announced the publication of a new web page outlining the results of a review it has undertaken of some larger firms’ Consumer Duty implementation plans. The firms in the sample have a dedicated FCA supervision team and which primarily operate in retail financial services markets.
Although there are a number of useful themes addressed in the examples of good and poor practice, many of which can be applied to smaller firms in all sectors, the sample of firms reviewed will not be representative of the insurance distribution sector. The FCA has, though, confirmed that it will soon be sending a survey to a broader sample of firms to help it understand the progress they are making in implementing the Duty, and it will carry out targeted engagement with smaller firms.
The review has highlighted three key areas where firms should particularly focus their attention during the second half of the implementation period (to 31 July 2023), those being effective prioritisation, embedding the substantive requirements, and working with other firms.
The key findings are set out under six main headings:
- governance and oversight;
- culture and people;
- third parties;
- the four outcomes; and
- data strategies.
To help firms implement the Duty, the FCA explains more on the areas of the Duty that it has been receiving firm queries on, which are relevant for the wider market. The FCA has also updated the page with information relating to requirements for firms seeking authorisation or seeking a variation of Permissions, including a list of the type of details a firm should include in their application if in scope of the Consumer Duty. Firms must prove that they can comply with the Consumer Duty.