Following Wednesday’s announcement from the FCA requesting progress updates on the Consumer Duty, Linda Gibson, Head of Regulatory Change, EMEA, BNY Mellon Pershing has commented on how to respond as an in-scope firm. Linda’s comment can be seen below:
The FCA’s ask for evidence of real progress on the Consumer Duty proves that its statement of ‘this isn’t a once and done event’ has real meaning. The Consumer Duty does not have a built-in regulatory reporting regime, therefore the FCA wants hard evidence that shows firms aren’t considering this a ‘job done’.
Now the request is in, firms should be going back to their Consumer Duty implementation framework and refresh it. Firms now have four months-worth of go live data and management information that will help determine their progress against the Consumer Duty’s four outcomes. It’s imperative they do not wait until the first annual board report is presented in July 2024, because at that stage firms will need to know what is working, what isn’t and therefore be clear about the changes that have already been made. Executives must be ready to have these discussions now and have the evidence to prove the basis of the decisions made and the required actions.
Overall, the FCA is looking for proof of a cultural shift and evidence that business models have and continue to evolve to become more customer centric. In its progress report, no firm should be complacent, there will always be areas to improve upon.”
