CONSUMER DUTY NEWSLETTER

So, where to start, if you’ve not yet started? Many firms have told me that sitting down and looking at a blank sheet of paper and knowing where to start has been the main issue. Procrastination is the enemy here, and I am still coming across firms that have not started their journey yet. If you are one of those firms then perhaps the below 10 tips might help you begin that journey. Tip 1 – Your plan needs to address the 3 cross cutting rules and the 4 outcomes – if you are not sure what these are then the immediate step to take is to watch our set of videos of which there are currently 4 all around 25 minutes long. If you want to cut down on watching all of them, then Part 2 and Part 4 would be my choices. You can access those videos here. Tip 2 – Start by thinking what management information you have available to you in your business, and what that information might show and tell you about your business. For example, where do your client leads come from – website, introducers, word of mouth? What does your sales process look like, if you could have all the time in the world to improve the process what would you do differently? Look at staff and client feedback, any complaints you may have had. Look at file reviews and see what the outcomes from those were, identify any gaps in your fact-finding process in how you communicate suitability or your fees. Do your fees need to be reviewed and do they represent good value for the service you give. Gather this information, no matter how irrelevant it might seem to you as this will help you focus on the areas that need improvement. Tip 3 – Involve as many of your Senior Team as possible in the planning phase. The FCA may call you post 31st October to discuss your plan. They may also call another Senior Manager within your business, so not including them in the discussions might mean they are unable to discuss the Consumer Duty with the Regulator which will raise concerns. Have a champion to drive it forward. Tip 4 – Think about the areas of your business that you know may be falling short, for example: cybersecurity, vulnerable client training, your suitability reports, your fact-finding process, your CPD and staff training/awareness, your internal communications, your website, technology, your introducers, your fees. Tip 5 – The next step is using those areas and action planning them into the consumer duty plan by thinking about how they all affect and impact on your clients. This will start to help meet the cross-cutting rules and outcomes that we have mentioned. For example, the cross cutting rule “acting in good faith” can mean explaining information to clients in an even- handed manner as to the benefits and risks of a product for a client and not exploiting a client’s vulnerabilities and perhaps lack of knowledge. Have a look at the below Hints & Tips for your Consumer Duty implementation plan Christine Newell, Mortgage Technical Director 12 CONSUMER DUTY NEWSLETTER Christine Newell Mortgage Technical Director Paradigm Mortgage Services