The new Consumer Duty applies very widely to all firms that “have a material influence over, or determine, retail customer outcomes”. It applies across the whole distribution chain, from product and service origination/manufacture through to distribution and post-sale activities. It also applies to the regulated activities and ancillary activities of all firms authorised under FSMA, the Payment Services Regulations 2017 and E-money Regulations 2011.
The Duty is seeking to set a higher standard of ensuring consumers are put first. In addition to delivering good customer outcomes, firms will be required to understand and, more importantly, evidence that the requirements of Consumer Duty are being met on an ongoing basis.
The Consumer Duty’s implementation period ends on 31 July 2023 for products or services that are open to sale or renewal and 31 July 2024 for closed products or services. Firms will need to consider the needs, characteristics, and objectives of their customers (including those with characteristics of vulnerability) and how they behave, at every stage of the customer journey.
Most firms will have a fair bit of work to do to satisfy the Consumer Duty. However, by the 31st October 2022 all firms should establish an effective implementation plan and maintain oversight of their delivery to ensure the implementation work is sufficient to meet the Consumer Duty standards.
Every firm has different needs and challenges to ensure they will be ready. Danos Consulting delivers flexible compliance solutions, that can assist you throughout all the key stages of successfully implementing the Duty and post implementationevaluation, we can provide support to:
- Effectively deliver and implement your Consumer Duty project.
- Interim resource to backfill expertise whilst employees focus on Duty deliverables.
- Resources for targeted assessments and delivery of the Duty.
- Deliver post Duty implementation assurance reviews.
Danos Consulting is a specialist resourcing and consultancy firm for leading organisations across Financial Services. We successfully provide resources to augment project delivery or deliver complete programmes of work. If you would like to discuss your needs further, please contact Gurjit Purewal who will be very happy to advise on the right solutions to ensure you are meeting your regulatory responsibilities.
Gurjit Purewal | Head of Consulting Solutions | Danos Consulting
E: firstname.lastname@example.org | T: +44 (0) 20 7610 6442.