Our Support Programme gave a number of gifts to the firms involved, none of which were partridges or pear trees!
The reason for our starting the Support Programme was to assist firms with the ‘how’ of Consumer Duty implementation into their businesses, moving away from all the headlines and getting to the nitty-gritty of the actual work. The session threw up a number of interesting points, which could help others in their planning towards the July 2023 deadline.
It’s easy to get caught up in admin, planning, filling in forms and other preparations which all make you feel like you are doing something – but is all of this effort worth it? Are you concentrating on the right things?
With your initial plan – is it realistic? Are the deadlines all falling at the same time – or have you considered leaving space for your day to day work? What about considering busy times such as end of tax year in March / April? Some tips from the session on setting realistic deadlines:
- Delegate where you can. It doesn’t have to be you that does ALL of the work, you may be responsible for the delivery of the whole ‘Consumer Duty project’ in your firm, but that doesn’t mean all of the work falls on you.
- (As an aside another good reason for getting other team members involved in the work is this will speed up the company ‘buy-in’ to Consumer Duty. The culture piece of this regulation requires that the whole company embodies the outcomes-based client-centric behaviour.)
- Ensure that, if you are relying on others to complete aspects of your plan, that you are taking their own work into account when the deadline is set so that priorities are identified and timelines are kept to.
- Work backwards from the last date that the work has to be complete, while thinking about how long the task will take in order to set the start date. Remember the FCA has said that preparation for Consumer Duty will (should) take the entire period from now until July 2023 – so do try to not leave everything until the last minute or not allocate sufficient time to a task/project.
Another aspect to consider including in the initial plan is training and the resource required for annual training – do you have the capability inhouse or would you have to outsource? Consumer Duty is an ongoing mission – it doesn’t just stop in July 2023, it will be how firms are expected to function going forward. There has to be provision for monitoring (systems and controls) and capturing the correct data to ensure this is done efficiently. Checking that processes are working in improving client outcomes (and understanding!) is an important part of the continuing success of the implementation.
This first session was ensuring that firms all have a good idea of their plans and tasks going forward, the next will start getting involved more specifically into their businesses. But basically from our point of view, those firms that are Consumer Duty compliant and ready for the deadline have a really good business model already, the support programme will make sure they have the written evidence to prove it!