Implementation plans played a vital role in accelerating the adoption of the Consumer Duty, with may firms initiating plans in Quarter 4 2022 to ensure they allowed sufficient time to meet the 2023 deadline.
The FCA viewed the development and successful completion of these plans critical to firms’ approach to the new Duty. Additional guidance was provided between Q4 2022 and Q2 2023 to assist firms implement the Duty and highlight where others had fallen short.
1
Identify the riskiest products that are provided on to retail customers
2
Prioritise the products by risk to consumer or identified vulnerability of end consumer
3
Create a clear assessment of the value provided by the product, considering both the marginal and absolute value of each product
4
Map consumer journey and touchpoints to your organisation and the extended distribution, services and claims providers.
5
Consider any gaps between the expectations of the Consumer Duty and your current culture. Design and implement any additional training or process as needed to meet these expectations.
1
Project governance, setup and decision-making and signoff engagement.
2
Definition of project objectives and their alignment with Consumer Duty outcomes.
3
Project timelines, engagement and critical success factors.
4
Identification and completion of ‘In Scope’ products / services assessments and enhancements.
5
Documentation and retention of product / service assessment, including assessment of core value metrics.
6
Development of value metrics to assess thematic and product / consumer type levels.
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