What can advisers be doing further down the distribution chain?
Despite the FCA extending the date by which businesses must adhere to the consumer duty rules, firms need an implementation plan in place by the end of October, notes Paul Bruns, director of consultancy services at SimplyBiz.
“The plan must be presented to the firm’s board or equivalent governance structure for scrutiny prior to this date, and firms should be prepared for the FCA to request sight of it.”
Indeed, compliance support provider Paradigm Consulting has been recommending firms set aside plenty of time to consider and undertake their implementation plan ahead of the deadline, according to its head of consultancy, Graeme Stewart.
“Depending upon the size and complexity of the firm, a collegiate approach may be appropriate in which every part of the firm is represented and involved in the construction of the implementation plan, for example advisory, admin and paraplanning staff,” Stewart adds.
Craig Ross, group proposition director at Sesame Bankhall Group, also suggests that a consumer duty project comprises the following three stages:
- Review and planning: assessing a firm’s existing proposition and services, baselining compliance with existing rules and identifying any gaps between these and the four new consumer duty outcomes.
- Analysis and design: potentially involving amendments to policy, process or systems.
- Implementation and measurement: beyond the July 31 2023 deadline there will also be a regular requirement to review and measure against the duty and its four objectives. Ongoing testing and reporting frameworks will therefore also need to be designed and established.
Chloe Cheung is a senior features writer at FTAdviser
