The New Consumer Duty Rules have been operational since July 2023 for “Open” books of business and will also apply to “Closed” books of business from July 2024. Should your Firm be lucky enough to be interviewed by staff from the FCA then here are a few furhter questions for you to think about. How would you respond and does your Managmeent Information (MI) stack up?
- Please explain how you prepared for Consumer Duty implementation and how you are continuing to embed this to ensure compliance. Please also provide details of how you have ensured your product assessments are compliant with PROD 4?
- What Management Information do you and your Board review and on what frequencies? (Governance book?)
- What specific Managment Information do you colate about the Customer Experience – including cancellation rates and reasons for cancellations?
- What remediation and enhancements have been implemented as a result of your root cause analysis this year? (Complaints MI: Overall complaints numbers etc; broken down by product)?
- Please provide copies of your policies and procedures including the sale process; identification and treatment of vulnerable customers; Compliance framework and your Quality Assurance processes.
- Details of the training process that new staff undertake including training about Conduct Rules and Vulnerable Customers?
- Details of how Vulnerable Customer Outcomes are tracked by senior management?
- Details of the checks undertaken as part of the affordability assessment for an advised sale?
- Deails of any Compliance Reviews undeertaken in the last 2 years?
- Details of the Firm’s Compliance and audit plans for the coming year?
Something to think about – if you are unsure of your current responses perrhaps we can help.