Consumer Duty: days to go!

With just a week to go until the final deadline for implementation of the final stage of the FCA's Consumer Duty, here is a reminder of what organisations who have FCA consumer credit or mortgage permissions need to do. 

1. Regulated firms should already have implemented the Duty for any “open products” (e.g. ongoing services and credit that is actively offered or marketed) before 31 July 2023.
2. The deadline for implementation for “closed products” (e.g. discontinued credit products such as historic loan portfolios) is 31 July 2024.
3. In each case, implementation of the Duty means that firms need to have strategised how they are addressing each element of the Consumer Duty, so looking at delivering good outcomes for customers in relation to the products/services offered, price and value, consumer understanding and consumer support throughout the lifecycle of the relevant product or service.
4. The FCA has made it clear that it expects input and approval from the Board and in particular that each regulated firm should prepare by the end of July 2024 a report for the Board to assess and evidence compliance with the Consumer Duty so far. 

We have seen a great deal of focus from our housing association clients on Consumer Duty in recent months and looking at how to manage the governance and board reporting aspect. We are working with clients on their Board reports and have a fixed fee package for a template Consumer Duty policy and guidance note. Please contact Alice Overton if you would like to discuss further.