Most of us acknowledge however, that there is often scope to improve as evolution is a constant and the Alliance, along with the FCA, have seem plenty of positive action, both pre and post the 31 July implementation date. It’s been especially encouraging to witness evidence of meaningful changes in line with the higher outcomes-based Consumer Duty expectations, rather than tick-box compliance with regulatory rules seen in the past.
Improvements in client communications and feedback capture have also been widely reported, although there is much more to be developed regarding the inconsistency of information flowing between manufacturing and distribution. Some of the Trade Associations, such as TISA, PIMFA and ABI are working on templates which will be most welcome.
We have also seen changes to fee structures, ongoing client support assessments/services and interest on cash accounts being passed onto clients by platforms, many in fairness, doing so before the FCA’s most recent Dear CEO letter. And we are receiving reports of regulated firms using Consumer Duty as the catalyst for reviewing their approaches to investments to find ways of reducing cost for clients and improving consumer outcomes. It has been interesting to witness firms reviewing their fee charging structures, with a strong emphasis on reducing cross-subsidy and removing conflict of interest.
The FCA’s webinar, Consumer Duty: The next steps, is available to view on demand. The key message is that we are at the start of an ongoing journey of positive evolution and all future regulatory supervision will be assessed against the cross-cutting rules and four key consumer outcomes…so every firm needs to be proactive in the interpretation and implementation, not waiting for regulatory action to drive change.
More recently, the FCA published a new webpage, Expectations of firms selling client banks, explaining their expectations of firms looking to sell a client bank, and that they will act where these lists are being sold with redress liabilities.
The Consumer Duty Alliance team are gearing up to expand support in 2024, with a range of new initiatives and good practice guides to be announced in the New Year.
- The Pensions Advice Taskforce - re-established in December 2023, under the Alliance, rather than the PFS, and Chaired by Margaret Snowdon, OBE. The board is made up of cross-sector representatives and attended by a technical observer from the FCA. The Pension Transfer Gold Standard is under review by the Taskforce, which may evolve into a broader Retirement Income focus and aligned to the findings of the FCA’s thematic work, due to be published during January 2024.
- Forums - with thanks to the Chairs of the Technology and Consumer Duty Champions' Forums, we'll also form two new cross-sector forums in the New Year focusing on New talent to the profession and Cross-border advice for UK consumers across the EU.
- Membership Growth - the growth in Alliance membership since our launch on 9 March this year has been phenomenal and we hope to exceed 20,000 members before the Summer of 2024!
Thank You to all of our Members and Affiliates for forming and being part of the biggest cross-sector Professional Alliance for Personal Finance in the UK.
Wishing you a Very Merry Christmas and a Happy New Year!
Keith Richards, CEO, Consumer Duty Alliance and Chairman, Financial Vulnerability Taskforce