Consumer Duty – one year on

It has now been one year since the Consumer Duty came into force for new and existing financial products and services. We are sure that firms will agree; it has been quite a journey so far!

The implementation of the Duty has been a somewhat phased approach. The financial services industry had deadlines in relation to approved implementation plans and information exchange requirements. We are now at the stage of the final, hard deadline set for firms under the Duty, that deadline being Annual Board Reports and closed products and services.

Over the last year, firms have been living and breathing the Consumer Duty. The 31^st July 2024 deadline now requires firms to have produced board-level reporting, covering their focus on good consumer outcomes as well as governance, culture and conduct. The deadline also brings into the scope of the duty, closed products and services.

The CCTA has issued guidance to members throughout their implementation journey. For board reports and closed products, we issued our latest guidance paper. Members can access his via the Member Hub.

The guidance paper provides useful information and advice around the content of your annual board reports. It covers aspects such as the type of data and information expected in board reports, what level of data would be appropriate, as well as proportionality and the layout and format.

We have always said that this is a journey, rather than a destination. Firms should be aware that the final deadline by no means signals the end of your focus on the Consumer Duty. Firms should continue to monitor the outcomes that retail customers receive and work not only to address any harm or detriment but look to improve on those outcomes throughout their business operations.

We remind firms to ensure that they have a particular focus on vulnerable customers to ensure that such customers are receiving, at least, as good outcomes as the wider target market.

The CCTA will continue to support and guide its members going forward. Look out for further communications as our dialogue with the FCA develops. No doubt the regulator’s focus will move from implementation and embedding of the Duty to reviews and insights into industry-wide compliance with the requirements of the Duty.

In addition, firms should continue to monitor the FCA’s Consumer Duty webpage for firms, which is regularly updated and can provide useful insights into the regulator’s expectations. This will also include information around their latest event ‘Consumer Duty- 1 year on’, held on 31^st July 2024. A recording of the webinar is now available. The event focused on the impact in this first year, examples of good practice, areas for improvement, and FCA priorities for the year ahead.

We will continue to engage with the regulator with the regulator as their insights on the Duty develop and it will continue to be a topic of discussion at many events, including our annual conference in October.

As ever, the CCTA Advice Line Service is available for any member seeking support and guidance on any aspect of the Consumer Duty. The CCTA team is happy to help as much as possible.