The UK's Financial Conduct Authority has conducted a review of firms' progress in implementing the new Consumer Duty for new or existing products by 31 July 2023 (and for closed products with existing customers by 31 July 2024). Firms had until 31 October 2022 for their board to approve their implementation plan and show that it has scrutinised and challenged the plans to ensure they are deliverable and robust. Since then, the FCA has checked on larger firms with dedicated FCA supervision teams and found that:
"some firms may be further behind in their thinking and planning for the Duty. This brings a risk that they may not be ready in time, or they may struggle to embed the Duty effectively throughout their business."
Aside from my February blog post here, I summarised the Consumer Duty requirements and key steps for implementation in a Keynote last September. That explains there is another recommended milestone at the end of April and the board must also oversee progress to ensure deadlines are met...
However, the FCA has published detailed findings across six aspects of the implementation process which shows where firms may be falling short. Generally, in the remaining six months to the end of July, the FCA wants firms to:
- ensure they are prioritising efforts where they are likely to be furthest away from the requirements;
- carefully consider the substantive requirements in reviewing products, services, communications, customer journeys and identify/make the changes needed; and
- work on all this with other firms in their distribution chain.
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