The question mark, he said, was whether there would be an easy route to switching to a new product.
"And that's where I think the FCA is going to look at it and say, 'Okay, people have got good products; where they don't have good products, is there a route for them to change or modernise that in some way?'"
Cultural shift
The consumer duty has created a cultural shift in the industry, away from treating customers fairly to treating customers well, which far from being a tick-box exercise has been fully embraced by the industry, says Royal London's Jenkins.
He says it had been positive and "strategic" and well thought through.
"It's not felt tactical from the FCA. If anything, the tactical stuff has come from government and the more strategic stuff is coming from the FCA.
"I think they've taken their time, they've consulted well, and you know, they're looking at strategic change rather than tactical intervention. And that's really welcome."
He adds: "You can criticise regulators for a lot of things, but I think in recent years, it's shown that it's got some strategic outlook and it's trying to drive things forward more positively."
Most of the work the FCA has done since, such as the retirement advice review and advice guidance boundary review, was done in the context of consumer duty, he says, adding that this further emphasises that there has been a cultural shift across the board.
One area where there have been lots of changes has been communication, he says.
"There has been a complete review of all the communications I think across the industry, people have sat down and said, 'Okay, what's the product – are we clear on who is using that product'.
"Is it the right target customer for that product, is it suitable, is it performing well, and indeed, how are we communicating those things?
"And are those communications clear, fair, not misleading? And where there are changes, you know, those changes have been picked up."
The difference, he explains, is now firms are looking beyond just treating their customers fairly at the point of sale, at what happened after they bought the product, whether it was a good outcome.
He says he would not expect consumers to have noticed the difference, however.
"If that were as stark a difference right through to the consumer, to see that you would think, 'Well, what were we doing before that?'"
Two phases
Jamie Jenkins says the fact the deadlines for different phases of implementation were spread out over a year was "quite helpful because there's probably quite a lot of learning across the industry from the first deadline and the assessment of value work that was done and how that now translates into looking at closed book-products".
