But I think we’ve all seen the updates from the FCA that have given real insight into what is expected of us, so I am optimistic that its intervention might not need to be too specific.
However, I am equally sure that if the FCA doesn’t see the consumer duty rules being adhered to, they will be quick to act.
FTA: Which challenges has consumer duty not been able to solve thus far when it comes to achieving good customer outcomes?
KS: In view of the potential number of parties involved in the distribution chain there are logistical challenges involved in obtaining all the data required to assess fair value and we hope that over time this will become easier, as the regulation and associated processes embed.
By the very nature of advice, the products available to meet client’s financial objectives, and tax and pension legislation, to name but two, we and the wider industry will continually need to be mindful of how we focus on simplifying the more complex aspects of some of the products we offer to ensure client understanding.
Finally, we’re concerned that clients with vulnerabilities still find it difficult to disclose these, so we’re doing some work with key partners to identify how we can make this easier for them, with our main target of improving client outcomes.
Carmen Reichman is multi-media editor at FT Adviser
