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Important Consumer Duty update for members – 5th December 2022

This note provides members with a summary of the current position on the work of the cross-sector working group which was formed to establish, in a non-competitive way, whether or not a common approach can be arrived at that could enable firms to demonstrate they are meeting the product disclosure and fair value requirements of the new Consumer Duty vis a vis mortgage lenders and intermediaries.

Update on deliverable(s) & timescales

As advised in our update on 21 November, the proposed deliverables were either a template (preferred) or a set of principles for use across the sector, capable of being adopted by lenders and intermediaries of all size and scale. Any output would be a living document, and one which would be adaptable for more complex products.

The Group has made good progress. We are in the final stages of agreeing a template, which we now expect to be in a position to deliver for wider consultation across the industry on 9 December, a week ahead of plan. At that time it will also be shared with the FCA and other key stakeholders.

The revised delivery plan over the next month is as follows:

Friday 9th December 2022: Baseline template agreed by the Group and then circulated by each Trade Association to their members for comment and feedback. Template shared with FCA and other key stakeholders, including the FLA and the ERC.

Thursday 22 December 2022: All comments from wider membership returned to BSA, via each member’s Trade Association.

Thursday 5th January 2023: Meeting of Working Group to review and consider feedback.

Wednesday 18th January 2023:  Final template agreed.

Members of AMI’s Consumer Duty working group are asked to ensure that colleagues are available and ready to review the template after it is issued and to ensure that all feedback is with us by no later than 22 December 2022. This is not least to ensure that we have an agreed template by 18 January 2023 to allow firms time to implement necessary process and technology changes.

Current position

Template: The draft is now in an advanced stage. Thanks to all members of the group for their support and input, and in particular to Ian Baker of Coventry Building Society for holding the pen. Key areas of focus have included:

  • Ensuring the purpose of the template is clear;
  • Product groupings;
  • Vulnerable customers;
  • Proportionality/level of detail/complexity; and
  • Consistency (in completion of end product).

Sourcing Systems: Discussions continue with providers of the four main sourcing systems and a key meeting is scheduled for Friday 9th That meeting will concentrate on two main issues:

  • Updating on progress of this group, and better understanding the potential for sourcing systems to build a portal or repository where firms’ assessments can be held centrally, and
  • Potential for data generation to assist firms in demonstrating their adherence to the duty.

Members will be provided with an update on progress with those discussions after 9th December.

Further updates will be provided over the coming weeks.