It’s been four months since the Consumer Duty Final Guidance was published and about 5 weeks (at the time of writing) since the first deadline for firms to get their implementation plans in place. At The Verve Group, we have spent a lot of time creating resources to help firms understand and implement Consumer Duty into their businesses (all of which can be found here), but I would suggest at this point that most firms have now got to grips with what Consumer Duty is, what the FCA’s expectations are and in which areas their businesses will require further attention and work to be compliant.
However, through assessment reviews and discussions with clients, we know that many are struggling the next steps – with the HOW. What has also become apparent from a number of the events we’ve run is that firms are also bored with being preached at, told over and over again what Consumer Duty is, but with no guidance on how to tackle it. The most common themes that arise time and time again in discussions that we have been having with many of our existing clients for the past few months and even years (client segmentation, PROD, pricing, CIPs, CRPs, having robust Platform Due Diligence, the list goes on), but having engaged with many new firms and non-clients through the presentations we’ve given with Nucleus, the PFS, Professional Paraplanner and our own, we’ve had a lot more questions about the ‘How’?
That’s where we come in.
On top of all the resource, events and information that we have already provided, we have now created a Support Programme for firms to come and discuss with us what it is they feel they need to work on and together (along with other firms) we can then all discuss how we think it could be achieved. One thing we’ve really learnt from hosting our MASTER workshops is that firms love to work with us in small intimate groups, where we can interact with each other and share best practice. Proper engagement, no death by PowerPoint (sorry, not sorry) and walking away feeling like they’ve achieved something tangible in a small period of time.
The Consumer Duty Support Programme has been designed around a timeframe that we believe will cover all of the key areas and common themes, in an order that should work around the information that providers and platforms will also be sharing their data. The initial focus is on the firm, its proposition, client base, target market and then the investment piece. Once this is clearer, we can begin to tackle the fair value assessment and due diligence, before we move onto how we plan to tackle the evidencing of Consumer Understanding and integrating this into your T&C scheme.
We’ve mapped out 10×1 hour sessions, the topics of 8 have already been planned out, with the remaining 2 to be decided as we progress and consider any tweaks needed along the way as we react to the provider and FCA feedback. Some firms have signed up for the 10 as a package, others have chosen the areas that they feel they need to focus on, the choice is there and we are very much open to people dipping in and dipping out as they feel necessary.
The one thing I have been so pleasantly surprised at is how engaged firms are with not just seeing Consumer Duty as a tick box exercise, but that it might just be the oh so gentle kick up the rear they’ve wanted and needed to fix some long-held frustrations or areas of the business that they know they can be better at. The other is that I think we all realise that we are all in this together and firms are very ready to roll their sleeves up and to help each other along the way. I am very much looking forward to getting this programme started and to see where it takes us (and the firms who are participating).
See more detail about the Programme here.
Christian Markwick, Head of Adviser Support.