Commenting on how IFAs’ ability to evidence compliance with Consumer Duty could be impacted by their third-party providers’ frameworks and processes, William Marshall, CIO of Hymans Robertson Investment Services (HRIS) says:

"As we reach the deadline for the new Consumer Duty regulations to be implemented, the processes and frameworks that firms have developed will start to do the heavy lifting. However, it isn’t just their own processes that advisers need to be sure that they’ve considered. For IFAs that work with third-parties it will be critical that they’ve also considered the arrangements that they have in place with their providers. Providers should be able to share documentation that sets out how they provide value for money and evidences how they’re carrying out their own processes, such as product testing. By ensuring that the providers are meeting the new requirements, advisers can have greater confidence they are fully complying with the new rules.

“Despite today being deadline day, IFAs that have yet to put these arrangements in place, still have time. They should make sure they have these vital conversations about their third-party partners’ frameworks as a matter of priority. An active approach here should help advisers prevent inadvertent non-compliance with Consumer Duty."