Countdown to the Consumer Duty: FCA provides 10 key questions for firms to consider

With just under a month remaining until the Consumer Duty Implementation Deadline on July 31, the FCA has published 10 key questions that firms can ask themselves in order to help identify and remedy gaps or areas for improvement in implementing the Duty. 

One thing is clear… 31 July merely marks the starting point and firms should prepare themselves for ongoing work on the other side of the deadline.

These questions not only reflect the FCA's focus, but also align with their previous guidance and feedback. This makes them an invaluable checklist for boards and Consumer Duty Champions as the implementation period draws to a close.     

The 10 key questions for firms to consider are: 

1. Are you satisfied your products and services are well designed to meet the needs of consumers in the target market, and perform as expected? What testing has been conducted? 
2. Do your products or services have features that could risk harm for groups of customers with characteristics of vulnerability? If so, what changes to the design of your products and services are you making?  
3. What action have you taken as a result of your fair value assessments, and how are you ensuring this action is effective in improving consumer outcomes? 
4. What data, MI and other intelligence are you using to monitor the fair value of your products and services on an ongoing basis? 
5. How are you testing the effectiveness of your communications? How are you acting on these results?  
6. How do you adapt your communications to meet the needs of customers with characteristics of vulnerability, and how do you know these adaptions are effective?  
7. What assessment have you made about whether your customer support is meeting the needs of customers with characteristics of vulnerability? What data, MI and customer feedback is being used to support this assessment? 
8. How have you satisfied yourself that the quality and availability of any post-sale support you have is as good as your pre-sale support? 
9. Do individuals throughout your firm – including those in control and support functions – understand their role and responsibility in delivering the Duty? 
10. Have you identified the key risks to your ability to deliver good outcomes to customers and put appropriate mitigants in place?

For further insight into the FCA’s Consumer Duty please visit our dedicated resource page.