In our discussions with clients, we know that many firms have already begun preparing for the Consumer Duty. Even though the FCA hasn’t finalised its rules yet, apparently that shouldn’t hold things up. The FCA is pushing firms to get a head-start now by, for example, looking for gaps between where you are now and where you’ll need to be under the new standards.

Challenger banks with significant retail business are among those who stand to benefit from a head-start. Like all firms, they need to pin down the scope of the incoming rules and map this to their existing product range. Unlike some firms, their business model may present particular challenges when it comes to implementing the rules and demonstrating compliance. Getting the Consumer Duty right is even more important given the wider supervisory scrutiny on the challenger bank sector.

Our latest note picks out some of the points for challenger banks to note on the Consumer Duty.