Consumer Duty and fair value: where are you now?
Following on from its 2020 review work with firms involved with Lifetime Mortgages, the FCA mentioned
Following on from its 2020 review work with firms involved with Lifetime Mortgages, the FCA mentioned again – in its Business Plan/strategy for 2022/23 – its concerns regarding the risk of poor (or unclear) advice in this sector.
The FCA has been following up with firms where it has undertaken previous supervisory work or visits in order to review progress. The regulator is expecting to see marked improvements given its output on the subject, including the various Dear CEO letters that have been issued to mortgage lenders and intermediaries.
The current environment potentially compounds the risks in this sector. For example, with the rises in both interest rates and inflation taking a massive toll, StepChange Debt Charity revealed in June that 45% of mortgage borrowers have found it difficult to keep up with bills and credit commitments in the last few months.
Similarly, the implementation of Consumer Duty has meant a refocus on delivering the forbearance and tailored support measures, which are most impactful for your customers when they are most acutely needed.
Download our guide to the FCA’s Business Plan 2023/24 for more insights.
TCC have assisted a number of firms who have struggled to initially meet FCA expectations and actively worked to help some of those firms avoid additional scrutiny and associated censures.
At TCC, we provide expert support to firms to give independent challenge and validation of firms approach to these rapidly changing risks and issues – and the more specific challenges arising from Consumer Duty implementation.
Let’s talk… Contact us for an exploratory conversation about your own individual views and risks. Plus get an introduction to who we are and how we build ongoing relationships with our clients on trust and value.