We know this is on everyone’s agenda and by now firms in sixteen separate financial services sectors will have received tailored FCA guidance. As the July deadline looms ever closer the FCA chief executive, while addressing a Treasury Select Committee, warned that Consumer Duty “will not go away”. At the same time, the regulator has stated the belief that some firms are over-confident about their Consumer Duty progress and that others are approaching the requirements too superficially.
With the current cost of living focus, mortgage lenders of all types are coming under the FCA spotlight. When considering the target market customers of the wide range of lender types, it is likely that a good proportion of customers will be considered vulnerable; in fact, recent research has shown that as many as 50% of customers can categorise themselves as having at least one vulnerable trait. Some industry trade associations, for example the BSA and Equity Release Council, are supporting their members with detailed guidance. While this is comprehensive and professional, it does not take away senior manager responsibilities to deliver their own Consumer Duty solutions.
The responsibility to deliver Consumer Duty rests with firms’ governing boards, who by now must have appointed a NED Board Consumer Duty Champion. We are already engaged with senior managers and Board Champions who acknowledge the need to ensure that appropriate challenge and oversight has been rigorous throughout the business, and that fair value and good consumer outcomes have been delivered. Now though, they are asking us “how do we evidence that in such a way as to satisfy the regulator?”
Firms looking for independent reassurance that their evidence is robust and that their conclusions are sound should consider giving us a call.