Consumer Duty has been in place for nearly five months and the feedback we are getting from industry compliance experts is that some firms are doing brilliantly, others are struggling, and a few haven’t even started.
But with the regulations now in place, time is of the essence. All firms (no matter what size they are) are expected to be on board and the FCA has made it clear that burying heads in the sand simply isn’t an option.
Data is Key
Before Consumer Duty came along, it’s fair to say that very few firms conducted regular analysis of hard data on vulnerability, the reason being that very few actually had any. Those that did have started to build up some of this valuable data, and nearly four months in, there’s an opportunity for these firms to assess what they’ve gathered so far, take stock, and see if their target market assumptions are playing out as expected. They could also look at how well any individual vulnerable customer has been supported, and with this knowledge, they can then determine whether their preparations were fit for purpose or if there are changes required.
Getting a head start on this process is exactly how firms will be successful in this area. The FCA is mandating an annual report on Consumer Duty but has advised not to wait until 31st July 2024 for firms to publish that outlook. The reason being that if any adjustments are required, a whole year won’t already have passed before those changes are implemented.
With that in mind, if a firm already has a mandatory internal reporting date – perhaps at the end or the beginning of the year – it may be good practice to consider tying their Consumer Duty reporting into that. It’s not mandatory of course, but it would be good practice.
Size isn’t Always Important
Naively, there are still some firms who believe they can postpone implementing Consumer Duty. Perhaps they think that being smaller means that they’re ‘safe’ and all focus will be on the larger firms. However, the regulator has been very clear that there will be no exceptions.
In other words, anyone who believes Consumer Duty isn’t being monitored is sorely mistaken. And while we have yet to hear of the FCA imposing sanctions, it’s sure to be only a matter of time before someone trips up and an example is made.
Next Expectations
Nearly five months in, everyone is progressing with Consumer Duty at different speeds – just as we saw before the implementation date. For the majority, firms are fully aware of the regulations and want to hit the nail on the head.
What’s clear, however, given the most recent guidance from the FCA, is the growing importance of data. The regulator is expecting firms to build their banks of vulnerability data, and that is where we’re starting to see a growing gap between those that are doing well and those that are falling behind.
We’ve spoken before about how the FCA never intended the 31st July to be seen as a finish line. Instead, it was meant to be the firing of a starting pistol which would mark the beginning of a broader conversation on vulnerability. And this is still very much the case.
We can now see what the next stage of this race is starting to look like. To those who are already making progress – they should be commended. And to those who have yet to act or who are falling behind, don’t delay. It isn’t too late to get your data in order.
What’s clear, however, given the most recent guidance from the FCA, is the growing importance of data. The regulator is expecting firms to build their banks of vulnerability data, and that is where we’re starting to see a growing gap between those that are doing well and those that are falling behind.
We’ve spoken before about how the FCA never meant the 31st July to be treated as a finish line. Instead, it was intended to be the firing of a starting pistol; marking the beginning of a broader conversation on vulnerability. And this is still very much the case.
We now know what the next stage of this race looks like. To those who are already making progress – they should be commended. And to those who have yet to act or who are falling behind, don’t delay. It isn’t too late to get your data in order.
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