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In August, the regulator published the latest in a series of consistent updates and analyses, which addresses several themes and concerns in the eyes of the FCA.
“Everything counts in large amounts”. So sang synth pop band Depeche Mode in their 1983 hit – a thinly veiled critique of corporate greed. In the age of an outcomes-focused regulator, however, does everything still count, in what amounts, and does it all add up to ‘fair value’?
Much like the Doomsday Clock, which counts down to the likelihood of a human-made global catastrophe, the Consumer Duty Clock is getting ever closer to midnight, when the first annual board report will be due.
Brokers have been caught up in the slipstream of a shift in sentiment prompted by financial scandals that have primarily not been caused by them. We also appear to see a change towards more direct human contact. After years of grappling with phone menus and online journeys littered with pop-ups and adverts, people want to be able to talk to another human being again.
Vulnerability is not new, although the use of that label has taken on a new significance in recent years. The FCA talking about Vulnerable Customers is not new either – launching their first consultation on the subject in 2019 and publishing their industry-wide regulatory guidance in February 2021.
The forthcoming Consumer Duty has received a lot of media coverage. Whilst much of this has been high-level, there is a key area in FG 22/5 that is yet to receive a spotlight in the wider press. However, it epitomises one of the key concepts behind the Consumer Duty – trust.