Consumer Duty: what's next?

The clear message is that the Consumer Duty is not "once and done", and firms must continually focus on good customer outcomes, with a big emphasis on the use of existing, and new, data to continue to learn, improve and deliver.

There were two specific areas that were called out by the FCA in relation to the next steps:

• 1. Closed products
• As expected, one of those areas is closed products, as this is the current focus of firms to be compliant with the Duty by 31 July 2024. Firms must ensure that customers with a closed product receive the right support at the right time, that customers are not put in a position of harm or detriment, and that they receive suitable communications and fair value.
• 2. Board reporting
• The second area of focus is the annual Board report. The FCA was clear that there should be evidence within the Board reports that delivering good outcomes is embedded within a firm's culture and should evidence that firms are on track to deliver their compliance with the Duty for closed products.
• In particular, Boards should be able to demonstrate that they are working with Executives to ensure compliance with the Duty, and that data is being used to evidence the delivery of good outcomes. There was an emphasis on this not being a tick box exercise and there will be a focus from the FCA on a data-led approach being used by firms. The FCA will be randomly selecting firms to test and challenge these requirements.