Following publication of its initial suite of documents designed to help firms prepare their Consumer Duty implementation plans (click here to view), AMI is working on a range of factsheets to provide a more in depth analysis of the rules and guidance, to assess the impact on our sector and to help firms understand what it is they need to do to meet the new standards. To assist firms with navigating and digesting the information, the factsheets will be split into different areas impacted by the Consumer Duty, with product specific factsheets covering protection, lifetime, seconds and BTL/CBTL.
In order to take outputs from our discussions with the regulator, lender trade body partners and AMI’s working group which will feed into our member guidance, we aim to publish the factsheets in December. This is a little later than we had initially anticipated but reflects our desire to ensure there is clarity on: roles and responsibilities between manufacturers and distributors; an understanding of how information will flow from lenders to intermediary firms and to ensure our factsheets reflect particular areas that are causing concern or challenge amongst mortgage intermediary firms or to particular firm types (such as smaller firms).
We believe we have supplied sufficient information in our initial suite of documents for firms to start their initial stages of implementation but if any firms have any specific queries please e-mail info@a-m-i.org.uk and the team will be happy to answer these for you. We plan to issue another Q&A document in the interim.
FCA trade association meeting
AMI recently attended an FCA trade association meeting and the following information is likely to be of interest to members:
The FCA has launched a firm facing Consumer Duty landing page. Click here to access. This will evolve over time and will be used by the FCA to provide key updates. Firms can sign up to FCA Consumer Duty e-mail alerts here.
The FCA is due to issue portfolio specific letters later this year (around November time). This will include some of the issues that arise in each portfolio (the FCA expect none of these will be new to the sector) and are designed to act as reminders of the issues in the portfolio that are relevant to the Consumer Duty, to ensure firms are incorporating these areas into their Consumer Duty implementation work.
The FCA shared its communication and engagement plans. This includes a series of webinars (see separate AMI newsflash) as well as regional ‘live and local’ events. AMI will share further details once known.
The FOS plans to share Consumer Duty case studies later in the year. These case studies will aim to set out a consumer journey for particular products (there won’t be case studies for each sector) and to highlight where the Consumer Duty should be thought about by firms. The FOS is working with the FCA to develop these.
FCA speech on Consumer Duty
Sheldon Mills, Executive Director, Consumers and Competition at the FCA recently gave a speech on Consumer Duty at the Consumer Protection in Financial Services Summit. Within this, he clarified that the FCA do not expect firms to have necessarily fully scoped all work required to embed the Duty by the October deadline, but firms plans’ should be sufficiently developed to provide their governing bodies (or equivalent, such as senior management/Directors) and the FCA with assurance that the Duty will be fully implemented for new and existing products by the end of July 2023.
Click here to read the speech in full.
