This note is a readout from a meeting we recently attended with the FCA. This will interest CCTA members who are involved in Consumer Duty implementation.

INTRODUCTION

As part of our policy and advocacy work, we attend the FCA’s regular roundtable meetings on Consumer Duty. These meetings, which are held specifically for Trade Associations, are a chance for the FCA to provide further detail. They could also provide insight into their expectations of firms with respect to Consumer Duty.

This is an opportunity for us to put forward key questions and challenges that our members face in implementing the requirements of the duty.

I attended the latest roundtable, which was held virtually, on 23^rd February.  The meeting focused on the FCA’s recent review of implementation plans. They also talked about their communication and engagement activity and an update from the Financial Ombudsman Service.

IMPLEMENTATION PLAN REVIEW

The FCA provided an overview of their findings from the review of implementation plans for larger firms. Their findings were published on 25^th January on their website.

The overview they provided was effectively a summary of their published findings, where they found evidence of both good practices and areas for improvement in areas. This included Governance and oversight, Culture and people, Deliverability, Third parties, the Four Outcomes and Data strategies.

They also re-iterated that where firms are falling behind on their consumer duty implementation plans, they expect firms to ensure they are continuing to focus on prioritising areas of greatest impact on consumer outcomes.

Firms need to make changes to ensure consumers receive communications they understand. As well as products and services that meet their needs. They pointed out the need to work with other firms in the distribution chain to ensure all parties are delivering good outcomes.

Whilst this review focused on larger firms, it is important to inform our members that the FCA will shortly be sending out a survey for smaller firms. This will be focused on their implementation plans. This is likely to be sent out “in the next couple of weeks” and will ask firms to provide responses to questions about their implementation journey.

COMMUNICATION AND ENGAGEMENT

The FCA was keen to highlight the work they have done with respect to industry-wide communication and engagement.

They pointed to the progress made here and made reference to their Consumer Duty webpage for firms. This included sectorial webinars, and a series of podcasts focusing on each consumer outcome. As well as their sector-specific portfolio letters.

It was good to hear that the communication and engagement activity will continue. They will be continuing engagement with trade associations and wider stakeholders and producing more webinars and podcasts.

Two important areas for our members are that the FCA has advised they aim to issue guidance communications around the April deadline for the exchange of information between manufacturers and the distribution chain.

FINANCIAL OMBUDSMAN SERVICE

Richard West, the Director of Casework Policy at FOS. gave a short update.

He was keen to highlight that they are also doing some work internally to understand and align with the FCA’s expectations on consumer outcomes.

He highlighted that they continue to work closely with the FCA on this. They again, reassured firms that their decisions will not be applied retrospectively.

You will have heard from our CEO, that the risk of a disjoint between the FCA and FOS has been a worry. We have expressed this point on a number of occasions.

As ever, we will continue to engage with the regulator on the Consumer Duty front and provide members with updates on any developments. If you have any further questions or queries in respect of the duty, please do get in touch. We will be happy to support you as much as we can.