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“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’?
Whilst acknowledging that most brokers and insurers in the study had taken steps towards improving their product governance, too many continued to fall short of the regulator’s high standards.
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.
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.