Assessing vulnerability: How can firms help mitigate risks of DIY SIPPs?
The FCA rounded up 2023 by publishing its findings into the retail banking Consumer Duty
This comprehensive publication has a read-through across all sectors of the financial service industry and reminds firms that they should expect the FCA to ask for their annual Consumer Duty board report. It will assess whether the firm is delivering good outcomes for their customers – plus firms may be asked ahead of the 31st July 2024 deadline about their preparedness for the assessment.
Since the Duty’s implementation for new and existing products at the end of July 2023, the FCA has been clear that ongoing governance must be a key element of embedding the Consumer Duty. It’s a top priority for boards and senior managers who are ultimately accountable and must be enforced through their Corporate Governance framework and wider ‘senior manager regime’.
It’s clear that time is of the essence
The annual ‘board report’ is not an attestation, it’s intended to be an essential piece of internal governance. Whilst the executive owns delivery of the Consumer Duty, boards have a critical role in setting the strategy and assuring the organisation is delivering the Consumer Duty and the right consumer outcomes.
Like everything else with the Consumer Duty, the board reports are not simply a tick box exercise.
The firm’s ‘outcomes monitoring’ is an essential feed for the board report. Any actions regarding a firm’s poor outcomes that have been identified will also need to have root cause analysis, impact analysis and a clear plan in place to be addressed and to prevent any further harm.
Impact analysis is particularly complex as this may affect live and/or closed products, approach to manufacture, distribution and back office. During the regulator’s December 2023 Consumer Duty webinar, it was confirmed that the FCA will be reviewing a sample of firms’ board reports and looking at the data included to evidence consumer outcomes – and looking at how effectively the board has scrutinised the firm’s performance and the actions planned to address any gaps.
With so much to consider, TCC’s compliance experts have compiled the Master your Consumer Duty annual assessment | Ten key questions to consider download, which provides firms with pointers on where to begin with their annual assessments – ensure to get your copy.
As regulatory expectations are so high, enlisting external independent expertise can be a diligent step to take – and TCC’s team of industry practitioners and ex-regulators are ready to help.
Get in touch today to discuss how we can work with you to make sure your firm meets its Consumer Duty expectations ahead of the 31st of July deadline.
Book a meeting with our Consumer Duty subject matter expert.