Marjolaine Quirke, client delivery director at Tenet Compliance Services, says a second pair of eyes and independent oversight will be top of advisers’ wish lists this Christmas:
“The Consumer Duty implementation timeframe has already been extended to next summer, but advisers shouldn’t expect the regulator to be delivering any more gifts this Christmas. It’s tempting to put things off but now is the time to get ahead on preparations to avoid waking up to a New Year’s hangover.
“The regulator’s deadline for firms to have their implementation plans in place has come and gone, so for advisers looking ahead into the new year, independent oversight of their hard work is the next piece of the puzzle.
“The Consumer Duty is straightforward at a high-level – all good businesses in any industry put their customers first. But, as ever, the devil is in the detail. The FCA has published well over 600 pages across discussion and feedback papers, consultations, guidance documents and policy statements. It would be all too easy to miss something – and for advisers keen to sleep easy this Christmas, now is the time to double down.
“In one sense the Consumer Duty is a new supervision tool but it’s also an acknowledgment that the previous approach was not always effective. Senior managers will now be held to account for their firms’ compliance with the Consumer Duty, and advisers will need to demonstrate both how they’re meeting the new rules and evidence how they record and monitor this.
“The move to an outcomes-based regulation does give greater latitude to firms but it also increases the risk of misinterpretation. Top of advisers’ wish lists this season will be a second pair of eyes to guide, steer and offer reassurance, which could be key to staying off the regulator’s naughty list when the new rules come into play.”