Consumer Duty - 10 Critical Questions to Ask
With just weeks to go until the Consumer Duty “go live” date on 31 July 2023, here are 10 ways to feel good or give yourself a fright!!
By Geoff Spencer, CEO
8 June 2023
(This is not a comprehensive list of what you need to do)
1. Have you appointed a Consumer Duty Champion and is the Champion providing detailed progress reports to the Board at least monthly?
2. Have you progressed your Implementation Plan from ‘initial’ to ‘final’?
3. Have you rewritten all your Corporate Governance framework documents to reflect Consumer Duty? (e.g. Strategic Plans; Risk Management docs; Statements of Responsibilities; Board and subcommittee Terms of Reference etc).
4. Have all staff received Consumer Duty awareness training so they understand both what it requires of them and the change to the Conduct Rules?
5. Have you defined what retail market business is, in your firm, and identified all your retail customers?
6. Have you completed a review of how your firm has complied successfully with the FCA PROD 4 Rules since October 2018? (Important for Outcome 1 – Products and Services and Outcome 2 – Price and Value)
7. Have you reviewed all communications (including verbal – such as scripts) to ensure that they can be understood by customers including those who are vulnerable? (Important for Outcome 3-Consumer Understanding and Outcome 4 Consumer Support)
8. Have you identified and established contact with others involved in your distribution chain to agree an holistic approach to implementing Consumer Duty?
9. Have you identified who in the business will be responsible for production of the Annual Report to the board and what the content will cover?
10. Have you established that your outsourcing partners will be able to support your Consumer Duty requirements?
To speak to us about how we can help you with Consumer Duty contact us at [email protected]