The industry is now in the final month ahead of the FCA’s Consumer Duty 31 July deadline. Last week, the FCA published 10 key questions for firms across the retail financial services world to ask themselves as they complete their preparations.
Aegon has produced its own set of 10 recommendations specifically for advisers.
Steven Cameron, Pensions Director at Aegon said: “With the FCA’s Consumer Duty July deadline fast approaching, and with so much material provided by the FCA, it can be hard to see the wood for the trees. The Consumer Duty further reinforces the need for providers like Aegon to collaborate with advisers. Building on the many adviser discussions we’re having, we have a number of recommendations to make.
“The FCA has published a wealth of information including some we’d particularly recommend revisiting. As well as the most recent FCA 10 key questions, it’s worth looking at the full set of 39 example questions. These appear in the Final Guidance which also includes a helpful list of suggested Management Information. The portfolio letter on Consumer Investments is also particularly relevant to advisers.
“In this final stretch, advisers will want to make sure they have all the necessary evidence in place. I’d recommend documenting not just what changes you’ve made, but also where you’ve considered an aspect of your business and why you concluded it already meets the Duty requirements. It would also be helpful to have a formalised record of how you identify and adapt your services where customers have characteristics of vulnerability.
“Once the Duty is live, the FCA is likely to take a particular interest in adviser value assessments, target markets and approaches towards segmenting clients. All of this should be documented and reviewed on an ongoing basis.”
Aegon’s 10 recommendations are as follows:
- Evidence delivery of implementation plan
- Review the FCA’s 39 example questions
- Document your target markets and segmentation
- Finalise value assessments
- Check your Management Information (MI) against the FCA’s suggestions list
- Formalise your approach to vulnerable customers
- Review your customer feedback
- Read the latest FCA material
- Keep prioritising
- Get your records in order
