At the halfway point, FCA's direction of travel and expectations on firms for the Consumer Duty are clear.

The FCA has reached the halfway stage of its journey towards Consumer Duty implementation:

Customer duty - graphic

Initial consultation paper published
(CP21/13)

Deadline for responses to CP21/13

    Second detailed
   consultation
   published

   (CP21/36)

Deadline for
responses to
CP21/36

Final rules
expected to be
published

Proposed implementation date (subject to consultation)

The Consumer Duty is designed to increase the current level of consumer protection in the retail financial services market. The FCA has signalled a "paradigm shift in its expectations" and therefore the impact of these proposals cannot be under-estimated in terms of its regulatory intentions. This is more than just repositioning and articulating existing requirements — it represents a raising of the bar with far-reaching implications for the retail sector. The FCA acknowledges that, although some firms may already be meeting some of these expectations, other firms will need to adapt or develop significantly to meet them.

The Consumer Duty's wide application reduces any `first mover disadvantage' that could be a barrier to firms making the appropriate enhancements. It is intended to be deeper than just a firm's policies and procedures — to go right to the heart of its culture, strategy and business.

The FCA is trying to drive culture and conduct changes, by placing an expectation that a firm's approach is embedded across the entire customer journey, and within each of its relevant parts. This initiative signals an intended destination of the FCA's journey to outcomes-based regulation.

This suite of articles include detail on the current FCA proposals, and how FCA supervision will evolve as it transitions to outcomes-based approach. The articles also seek to provide practical insights on the implications for firms from these heightened expectations, and ways in which KPMG professionals can support firms with their understanding and implementation of the proposals.

  

  

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