The regulator warned firms they have to embed customers’ interests centrally in their culture and purpose, across strategy, governance, leadership and people policies, not just compliance.
Nisha Arora, director of cross cutting policy and strategy at the FCA, said during a speech on Wednesday (1 November) that firms need to make sure they are «learning and improving continuously» and must be able to evidence this in their annual board report.
Three months since the initial 1 July deadline for implementation of the Duty, she said the FCA has seen some good practices and benefits for consumers.
One such benefit is firms reviewing their fees with fair value in mind, the regulator said. The FCA stopped short of naming the most high profile example of this in St James's Place, which recently overhauled its charging structure.
Deep Dive: Consumer Duty is 'forcing' DFMs and asset managers to justify value and costs
Other positive changes include firms simplifying language in the letters they send customers and introducing more accessible formats. Firms are also being more upfront on their websites about exclusions so it is easier for customers to understand whether a product meets their needs.
Many firms have approached the Consumer Duty «in the right spirit», Arora said, using data and insights to put themselves «in their customers' shoes», to deliver the right outcomes and improvements to their products and services.
But she cautioned the Consumer Duty is not «a once and done event» where you can «tick the Consumer Duty box on your to-do list and move on».
It needs to «become part of who you are as a firm, your culture, and how you do business», from board to front-line delivery, from product design to communications and
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