FCA highlights areas of focus for firms implementing the Consumer Duty

Following the review of the implementation plans as regards the new consumer duty of „larger fixed firms“ with dedicated FCA supervisory teams (please see EventID 19277 in this context), the Financial Conduct Authority, FCA, has published another press statement in this context. Therein, the Authority highlights the key issues firms should focus on in the remaining six months before the consumer duty comes into force. These include the following:
1. Prioritization: Firms need to prioritize their activities based on the level of „impact on outcomes for consumers.“
2. Implementation of changes: Firms must ensure to make all necessary changes in their product design, distribution, disclosure, and pricing policies to meet the requirements set out in the policy statement.
3. Cooperation with partner firms: Firms need to get in touch with their partner firms (e.g. a PRIIPs distributor with the insurance company and / or management company of the investment fund that is part of a PRIIPs to ensure adequate, timely communication, for instance, as regards the evaluation of the target market).
As the FCA observed some firms being behind in their planning for the new consumer duty, the FCA concludes by noting that there’s still sufficient time to „get things right“. But action needs to be taken now.