Commentary

Comment on the FCA consultation on Consumer Duty

30 Jul 2021

Commenting on the FCA Consultation on Consumer Duty, Stephen Birch, Managing Partner Investment Services, Hymans Robertson Investment Services, says:

“We, like many firms see these Consumer Duty proposals as an opportunity to strengthen and build on good consumer practice and will embrace and embed this into policy and process. They also present a chance to further develop how firms work with client vulnerabilities and behavioural biases, an area the FCA has been focused on for some time and which has been heightened during the Covid-19 pandemic.

“For some firms, however, we anticipate that this will be seen as further regulatory work to be factored in and they may find it tricky to articulate what the FCA is seeking in relation to good outcomes. Having a clear sight of what practical steps should be taken from product design through to client service and communications will be key. This will require firms to thoroughly review current practices against the new higher standards proposed. To get the application of this right it will be important to put the consumer at the centre of material decisions. They must ensure that all steps have been taken to allow the consumer to make their own informed decisions about their investments.”

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