FCA's review of implementation of Consumer Duty

Key findings include:

• Just over half of the 23 firms assessed were rated satisfactory who did not present a risk of significant poor consumer outcomes;
• Just under half of the assessed firms had only partially implemented the Duty and required significant work to comply with it;
• The best firms clearly articulated customer-centric purposes, and had strong governance and control frameworks in place to scrutinise and challenge the firm’s implementation of the Duty; and
• The highest rated firms often adopted a systematic implementation approach.

Payment firms including PSPs and EMIs should review the findings and take any appropriate action to ensure products, systems, and controls are aligned with Consumer Duty requirements.

💡 For a reminder of Consumer Duty obligations, revisit Plenitude’s paper, ‘It’s Your Duty to be (Consumer) Dutiful’, to learn more on the FCA’s expectations for businesses to treat customers fairly, ensure good outcomes, and demonstrate appropriate compliance. https://www.plenitudeconsulting.com/news-insights/plenitude-insights-its-your-duty-to-be-consumer-dutiful