Long Read  

Keith Richards: Five things to know about the Consumer Duty Alliance

  • A network for good practice and support in respect of good consumer outcomes.
  • An independent voice for the personal finance sector.
  • Consumer recognition of an independent code of professional standards aligned to consumer duty.
  • Signposting to appropriate organisations, support services, networks and qualification bodies.
  • A basis for collaboration across professional services.
  • Focused forums involving subject matter experts.
  • Detailed good practice guides in respect of key aspects of both consumer duty and drivers of vulnerability.

Richards adds: "Regulated financial advice is all about delivering good outcomes. To that extent the consumer duty is nothing new. What is new is an explicit requirement to robustly evidence this outcome during the whole consumer journey."

The CDA will continue to focus on the issue of vulnerability but in the wider context of consumer duty where it now sits.

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Alliance structure

There are three main strands to the alliance.

The first is the financial planning forum, which will be chaired by Nick Cann, former chief executive of the Institute of Financial Planning.

It will consist of invited practitioners to help create thought leadership, good practice guides and financial planning methodologies supporting the wider development and evolution of financial panning as a practice, aligned to firms' consumer duty objectives, including approaches to vulnerability.

The second is the tech forum, which will explore how technology can help firms to meet consumer duty requirements, for example evidencing the delivery of good client outcomes. 

Richards says: “The consumer duty guidance comes with a significant requirement for evidence and many firms are reviewing their data-driven technology solutions as a result. 

“The forum, under the chair of Ian McKenna of the Financial Technology Research Centre, is about exploring how technology can both evidence and support good client outcomes as well as the broader objectives of the duty, increasing access to advice and what’s available to firms right now.”

The third strand is the champions forum. The genesis of this forum came from conversations with Johnny Timpson, protection specialist and industry veteran, about providing an opportunity for consumer duty champions to discuss key issues and challenges around the implementation of consumer duty. 

Richards explains: “These champions are independent non-executive directors of firms whose role as far as the regulator is concerned is to ensure that consumer duty remains prominent at board level discussions, and to challenge a firm’s governing body/management on how it is embedding the duty and focusing on consumer outcomes. 

“The aim of the forum is to support this role through exposure to new and shared ideas from other ‘champions’ as well as best practice across the sector. Participation will be open to consumer duty champions, compliance directors and other appropriate CDA members.”

Membership 

CDA is a free to join membership body open to regulated firms and all individuals working in the personal finance sector. 

Richards says: "It’s not our intention to charge a fee for membership. All need to adopt an independent code of professional standing, consumer guide and financial vulnerability charter. Adoption can help firms and individuals by referencing as a segue to introducing their professional services and commitment their client duty.