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PIMFA WEEKLY NEWS BULLETIN 10 July 2023
Consumer Duty Corner Deliverability for 31 July 2023 Based on an insightful presentation from our Associate Members Beyond, below are areas to consider in enabling delivery of Consumer Duty implementation. 1. Evaluate your implementation plan
2. Ensure alignment to Consumer Duty and
It may be helpful for firms to assess their progress
prioritise the FCA’s expectations
to date and ensure a plan is in place for 31 July e.g.:
•
Following the FCA’s fair value framework
a. Ensure your focus aligns to the FCA’s key
review and Sheldon Mill’s speech (10 May
priorities for 31 July – be clear on what is
2023) – firms should consider the FCA’s
needed and what is being done with board level
areas of focus (consumer protection,
support
outcomes and data, a customer centric
b. Ensure you have done enough to be
approach, reducing harm, delivery of
materially compliant and make sure you
good outcomes) and their intention to
evidence it – e.g. fair value assessments,
prioritise serious breaches
measuring and monitoring outcomes, appropriate
•
Key areas of focus include fair value
segmentation and consideration of vulnerabilities -
(especially vulnerable and low income
articulate time and resource devoted to
consumers given the cost of living crisis)
implementation
and approaches to monitoring data and
c. Be proportionate on what must be done by
differential pricing
31 July – focus on areas of highest risk by prioritising changes that impact fair value and
•
Firms should consider governance, benchmarking, pricing and margins and