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CONSUMER DUTY

The Consumer Duty is intended to ensure a higher standard of care across financial services for retail customers and to deliver good consumer outcomes throughout the life cycle of products and services.

The Consumer Duty is a significant regulatory change with a need for a shift in culture and mindset to focus on delivering good outcomes for retail customers. The Consumer Duty is subjective and requires a holistic approach: firms need to consider the application of the duty in line with their size, type and role within the distribution chain.

The Consumer Duty aligns with the Financial Conduct Authority’s (FCA) business priorities focused on consumer outcomes and reducing and preventing serious harm. The FCA is increasingly focused on addressing consumer harms, particularly given the rise in customer vulnerability (as shown by responses to the FCA’s Financial Lives Surveys). The Consumer Duty intends to create a higher level of consumer protection in retail financial services, with the FCA highlighting their data-led and outcomes-based approach to supervision.

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PIMFA responds to FCA CP 24/30: A New Product Information Framework for Consumer Composite Investments

In our response to the Financial Conduct Authority’s (FCA) consultation paper CP 24/30, we fully recognise and support the need to overhaul the disclosure regime, however, it is our view that the requirements need to be considered in aggregate. Proposals should be designed with Consumer Duty, specifically consumer understanding, at the core.

We are calling for simplicity in approach, clearly defined responsibilities, and a coherent roadmap of planned change and interdependencies.

Read our full response here.

Following a review of firms’ approaches to consumer support, the Financial Conduct Authority (FCA) has published good and poor practice on how firms are approaching the consumer support outcome of Consumer Duty.

Noting that firms must find their own approaches to embedding the Duty, based on their size, activities, and resources, the findings set out areas for improvement, such as aligning support processes to the target market and embedding a culture aligned to Consumer Duty.

The FCA also highlight good practice, for example, building a culture that delivers good customer support outcomes, and monitoring whether customers are receiving the support they need.

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