No doubt you’ve seen all the Consumer Duty content floating around – it’s hard to miss that there has been a huge piece of regulation released recently. But just taking a breath and a step back from all the shouting about “it’s here! It’s here!” allows you time for a more considered question: “so what now?” 

Well, because it’s us – firstly we’d recommend that you read through our guide as it does give you an overview of what Consumer Duty is and breaks down the four outcomes in a clear and simple way. Secondly (again in a calm and measured fashion) it’s time to look at your business as a whole and consider whether there are any gaps in process, procedure or service that need to be filled. Remember that the FCA has requested that a firm’s board, or equivalent, must have agreed and signed off Consumer Duty implementation plans by October 2022. That’s only a couple of months from now. You have to initially understand what, if anything, needs to be changed / updated, then work out the best way to do that to stay compliant. 

Obviously, there are a number of important aspects in the final FCA paper, but one that stood out to us the most was the emphasis on vulnerable clients. Complementing the previous guidance on the treatment of vulnerable customers, The Consumer Duty reinforces the standards and expectations already set out, but it’s not surprising considering the exponential rise in clients who would be considered vulnerable over the past couple of years due to the pandemic and rise in living costs. The FCA have specifically told firms to review their processes and procedures around this (including in communications) and to ensure that all members of their team are trained in all aspects. This would be a very good place to start with your implementation planning. 

It is hard to evidence such nebulous concepts as ‘culture and behaviour’ and ‘value and service’, but that is the overall concept of Consumer Duty for firms. It’s a huge shift in expectation and may be what the industry needs to gain trust from the end clients once more. Financial services has taken some large hits over the last few years in the press (bailout of banks, DB transfer mishandling, crypto currencies) and you can understand why people may be wary of trusting financial institutions with any money at the current time. 

Consumer Duty has been designed to ensure that any decisions, at business level or down to a personal client level are made with the outcomes for the end customer in mind. Be able to evidence that you are doing everything the FCA is asking for and make sure the customer is at the heart of everything you do. Every journey starts with one step – you just have to take yours.


Find out more about Consumer Duty here.