Consumer Duty – Where to focus post implementation

The introduction of the Consumer Duty at the end of July 2023 marked a dynamic shift in the FCA’s focus and the expectations on insurance intermediary firms.

Many insurance intermediary firms worked hard to meet the initial July 2023 deadline for implementing the Consumer Duty within their risk and control frameworks. However, many firms are now considering where they need to focus their attention to ensure key requirements remain embedded.

Join me through this series of blog posts where I consider the impact of the Consumer Duty on the insurance intermediary sector and highlight some key questions and challenges that executives and non-executives should raise to gain comfort on their firms activities.

Consumer Duty

The Consumer Duty set a new, higher standard on financial products, services and providers ensuring that firms put the interests of retail customers ahead of their own commercial objectives.

The FCA clearly defines their expectations on firms through the Consumer Duty, which includes:

• A Consumer Principle (Principle 12) – ‘Firms must act to deliver good outcomes for retail consumers’
• Cross-cutting rules
  • Act in good faith towards retail customers
  • Avoid foreseeable harm to retail customers
  • Enable and support retail customers to pursue their financial objectives
• Four specific outcomes
  • Products and Services
  • Price and Fair Value
  • Consumer Understanding
  • Consumer Support