FTA: Is there a risk of more spurious complaints/CMCs pushing for redress under consumer duty?
CM: The overarching objective of the consumer duty is to improve client outcomes. Happy clients are unlikely to complain so providing firms look after their clients I think this is an unlikely consequence of the regulation.
FTA: How often should a firm review whether they're giving fair value - and do they do this for every client, or every segment?
CM: This could be an enormous and never ending task if they don't standardise it. This would be a firm decision and would be for them to decide how often to review fair value.
FTA: Could consumer duty risk pushing up the cost of financial advice/preclude more lower earners from seeking advice?
CM: A reduction of complaints will over time reduce the amount of compensation paid by the FSCS which in turn will (in theory) lead to a reduction in the amount FCA regulated firms are required to pay towards the levy each year.
This will take time, but over the longer term the consumer duty should result in firms paying less towards the levy giving them the ability to help those who are not currently able to benefit from professional advice.
