When asked to what extent the FCA expects firms to monitor customers’ protected characteristics, Smith said that there are already requirements for this under the Equality Act and data protection legislation.
“Firms should clearly ensure they’re aware of their obligations under that legislation and collect data in line with those obligations,” Smith said.
“We're conscious, for example, that collecting and monitoring data about customers’ protected characteristics is not always going to be possible. However, where firms do already collect that data, you know, we would expect them to use that to monitor differences in outcomes between different groups with different protected characteristics,” he added.
Other regulations
Smith also explained that where a firm is already obliged to comply with existing regulation, this may mean they are meeting the requirements of a consumer duty outcome.
For example, the consumer duty’s products and services and price and value outcomes are not new to firms in the general insurance sector or pure protection firms.
“If those firms are already complying with the Prod rules and for general insurance firms, if they're already complying with our general insurance pricing practices interventions, then they'll already be meeting our expectation under these two of the duty’s four outcomes - the price and value and the products and services outcomes,” Smith said.
jane.matthews@ft.com
