It’s almost 12 months on from the 31st July implementation deadline – so what’s next?
With the Consumer Duty implementation date well and truly behind us, many Brokers are eager to know what lies ahead. Firms that operate “closed” products need to complete their fair value assessments by 31st July. A “closed” product is one that was sold before 31st July 2023 but hasn’t been marketed or sold to new customers since (or renewed). We suggest that firms just think back to make sure they’re not receiving any ongoing fees from customers (e.g. recurring fees agreed pre–Consumer Duty), and then consider any Fair Value Assessments issue by providers.
Perhaps more important for our TMA firms though, is the other impending deadline on the horizon. The annual assessment (Board) report. The deadline for completion is 31st July.
It’s not optional or a ‘nice to have’. It’s required to demonstrate your firm has carefully assessed Consumer Duty. It’s for you to demonstrate your firm is delivering positive outcomes for your customers.
You’ll need to do this each year from now on!
The FCA could request sight of your annual report at any time. It might be this year or next year – and don’t be surprised if any future request also asks for past reports at the same time!
There’ll be lots of “shared content” and “articles” for you to read, but we think you need to ask yourself four key questions:
- How you think are you doing against the Consumer Duty Outcomes?
- What you’ve done differently?
- What you think you might need to do differently moving forward?
- If you didn’t make any changes to your business and how you deal with customers, then do you have evidence that you didn’t need to make any changes?
Be prepared! The FCA requires firms to finalise their Annual Assessment (Board) Report by 31st July 2024, documenting any changes made to their business.
TMA have provided all compliance users, access to a document containing guidance and a checklist to support you with your report. Click here to access the vault and download your copy now.
If you’re not a current compliance user, get in touch with the Broker Support team on 0330 303 0236 for more information about our compliance offering.
By Martin Sykes, Operations Compliance Director, LSL
