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Writer's pictureSimon Roberts

"Driving Cultural Change: The FCA's Latest Address on the Consumer Duty Implementation"



The Financial Conduct Authority (FCA) remains steadfast in its commitment to instilling a lasting cultural shift within financial firms as it addresses the Consumer Duty three months after its implementation. Nisha Arora, the FCA's Director of Cross-Cutting Policy and Strategy, recently delivered a speech emphasizing the evolving nature of this Duty, emphasizing that it's not a one-time compliance event but rather a pivotal catalyst for transforming how businesses engage with consumers.


Arora stressed the importance of integrating the Consumer Duty into a firm's culture, permeating every aspect of operations, from the boardroom to customer-facing roles, product design to customer support. The goal isn't just to comply but to effect an enduring change in the way businesses function and serve their clientele.


Successful implementation, as highlighted in the speech, revolves around acknowledging and embracing this significant cultural and behavioural shift. Some exemplary practices exhibited by firms include simplifying customer communication, making information more accessible and transparent, and reconsidering fees to ensure fairness and value for consumers.


A cornerstone of successful implementation is data. Firms that succeed in meeting expectations are those adept at identifying and utilizing the necessary data to gauge and monitor outcomes. Conversely, firms that fall short often only repackage existing data without seriously considering the information required to truly understand consumer outcomes.


Looking ahead, the speech outlines key actions for firms. These include reviewing implementation plans, ensuring changes made align with the spirit of the Duty, and staying on track for the implementation deadline for closed products and services, emphasizing the need to prevent foreseeable harm or frustration for customers pursuing their financial objectives.


The FCA, too, sees the Consumer Duty as an integral part of its approach across the regulatory life-cycle. From authorizations to policy development, supervision, and enforcement, the FCA aims to test and encourage firms' implementation and integration of the Duty. The regulator will adopt a robust stance where needed but also aims to highlight and share examples of good practice within firms.


In support of ongoing understanding and alignment with the FCA's expectations post-implementation, a webinar is scheduled for December 6, 2023, where the regulator will provide further guidance and insight into its continuing expectations.


In essence, the Consumer Duty stands not as a mere regulatory checklist but as a driving force for reshaping the financial landscape, emphasizing consumer-centric practices and fostering an enduring culture of responsibility and transparency within financial institutions. The FCA's ongoing commitment and guidance serve as a compass for firms navigating this transformative journey towards consumer-centricity.

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