CONSUMER DUTY NEWSLETTER

It’s fair to say that this year has been dominated by the issue of the Consumer Duty, and whilst firms should not be alarmed by the new higher standard of rules, there is a fair bit of work to be completed. Paradigm are here to help and support you on every step of the way. Clearly the first, most immediate task to complete if you have not already done so, is to establish your Consumer Duty implementation plan, which was due to be in place by the 31st October 2022. This article will focus on hints tips and guidance which we hope will help you with these preparations if you have not yet finished your plan. Start with the end in mind The FCA want you to create your own plan so that you are fully invested in reviewing your business to ensure that it is ready to meet the Duty’s requirements. Should they ask to review your plan, they will want to read, understand and gain assurance that: • Your firms’ Governance arrangements are under the oversight of the appropriate SMF and up to date and aligned to meet the Duty requirements • There is evidence that all staff are fully trained on what is expected under the Duty and the appropriate SFM has close oversight of this • All SMFs in the business are aware of what is going on, working together to consider future business plans and foreseeable risks to the business are being considered do not hinder meeting the Consumer Duty Requirements • You will be able to generate MI to evidence Consumer Duty outcomes • SMFs have full oversight and control Consider your plan to be like a Fact Find We are finding in the field that if a firm starts considering their implementation plan, rather like a fact find, it really helps. Try to disconnect from the day to day and consider reviewing your business from the point of view of an outside third party looking in, trying to understand what’s going on, what the firm’s objectives are. The FCA are the outside third party. Use the key questions in the guidance document and really explore the answers, thinking about what a third party might ask you, for example: • Why do you do it that way? • When is it done/reviewed/updated? • Who does it/who is responsible? • What strengths and weaknesses have been identified from your review and how is your plan going to address any weaknesses? • How is the plan going to be reviewed and implemented? • Where is the evidence of the outcomes/monitoring/reviews of the plan? Preparing your plan... Graeme Stewart Head of Consultancy Paradigm Consulting 8 CONSUMER DUTY NEWSLETTER