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As the 31 October 2022 deadline has passed, the FCA expect firms to have completed and documented their implementation plans for Consumer Duty. Firms are not required to submit their plans to the FCA but should provide a copy if asked. We are aware the FCA has started to request plans from some firms and await to see if the FCA publish industry wide feedback.

Firms’ focus should be on implementing the Consumer Duty requirements. The AMI team has been working hard to prepare member factsheets and our plan is to issue these to members before the Christmas break.

We’re also aware the FCA will be issuing a portfolio letter to firms, signalling areas that have been highlighted in previous Dear CEO letters which firms should consider as part of their Consumer Duty work. Our expectation is that this will be issued by the FCA before Christmas.

A recent speech by Nikhil Rathi reaffirmed that the Consumer Duty will not apply retrospectively, with conduct being judged on the rules and standards in place at the time. It also highlighted that the FCA will be monitoring the impact of Consumer Duty on financial inclusion to ensure firms do not become risk averse to difficult to reach groups of consumers.

Finally, you may have seen a recent update from AMI on its cross trade body working group. The group’s aim is to develop fair value and target market templates to be used by lenders to enable a consistent approach to information sharing with intermediary firms. We will continue to keep our members updated on progress.