Written by Steven Cameron, Pensions Director at Aegon
We welcome the FCA’s Call for Input around how its rulebook might be streamlined as a result of the Consumer Duty. This is something Labour had said it would ask the FCA to undertake.
Firms are embracing the Consumer Duty with its focus on delivering good consumer outcomes. The FCA is encouraging a flexible approach and it’s right to reflect on whether there are areas of the FCA’s rulebook which are unhelpfully prescriptive or simply no longer needed.
We’re pleased to see the Call for Input refer to the Advice Guidance Boundary Review. Rulebook changes will be needed to make sure individuals can get the help they want, when they need it, at a price they can afford. The current advice guidance boundary has left a ‘support gap’ that needs filled.
One area which might benefit from simplifying the rulebook is disclosure. The Consumer Understanding outcome within the Duty is very relevant here.
However, there are times when having prescriptive rules to follow can be helpful to firms, or needed for consumer protection. When responding, we need to ‘be careful what we wish for’.
