Consumer Duty
What is Consumer Duty?
Consumer Duty is the new regulated framework that dictates the level of care firms must provide, ensuring they always act in the interests of consumers through the full life cycle of the products or services they offer.
It is comprised of a new Consumer Principle 6 defining overall standards, three Cross Cutting Rules defining an expected structure of behaviours, and Four Outcomes that all consumers should expect:
A firm must act in good faith to deliver good outcomes for clients.
- Act in good faith towards retail customers.
- Avoid causing foreseeable harm to retail customers.
- Enable and support retail customers to pursue their financial objectives.
1. Products & Services.
2. Price & Value.
3. Consumer Understanding.
4. Consumer Support.
Regulated firms will have to be ready for the upcoming deadlines below:
- Apr 2023: Firms must have finished their review of new and existing open products and services.
- Jul 2023: Firms must be able to evidence compliance vs new and existing products and services.
- Jul 2024: Firms must be able to evidence compliance vs closed book products and services.
What are the four outcomes?
Requirement:
To achieve Outcome 1 of the FCA Consumer Duty Act, firms must ensure that their products and services are fit for purpose. This means designing products and services that meet the needs of their target consumers and that work as expected.
Resolution:
Firms should ensure that the terms and conditions of their products and services are transparent, easily understood, and do not contain any unfair or misleading terms. They should also provide clear and accurate information about the features and benefits of their products and services.
Requirement:
To achieve Outcome 2 firms must ensure that their products and services are sold at a price that reflects fair value.
Firms should not charge high fees or commissions that do not reflect the fair value of the products and services they are providing.
Resolution:
To ensure transparency, firms should clearly disclose any fees and charges that the customer may incur. This includes ensuring that costs and charges are associated with products and services are clear, concise, and understandable.
Requirement:
To achieve Outcome 3 of the Consumer Duty Act, firms must ensure that consumers are equipped to make good decisions. This means providing information that is clear, concise, and understandable, so that consumers can make informed decisions about the products and services they are considering.
Resolution:
Firms should make sure that the information they provide is relevant and timely, and that it is easily accessible to consumers. This includes providing information about the risks and benefits of the products and services and ensuring that consumers understand the potential costs and charges associated with them.
Requirements:
To achieve this Outcome, firms must ensure that their customer service is responsive and helpful. This includes making it easy to complain about products and services and if applicable switch or cancel if not satisfied.
Resolution:
Firms must provide clear Information about how to make a complaint and should look to handle complaints in a timely manner. They should provide clear Information if the customer wishes to switch or cancel products and services and should not face unreasonable post sale barriers or charges.
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