Consumer Duty Implementation Support and Advice

In July 2022, the FCA published its policy statement, PS22/9 – A New Consumer Duty (the ‘Consumer Duty’), in which they introduced new rules to ensure financial services firms recognise the impact their services and products have on the consumer and provide a safeguard against exploitation.

The FCA said that the Consumer Duty will include requirements for firms to:

  • end rip-off charges and fees
  • make it as easy to switch or cancel products as it was to take them out in the first place
  • provide helpful and accessible customer support, not making people wait so long for an answer that they give up
  • provide timely and clear information that people can understand about products and services so consumers can make good financial decisions, rather than burying key information in lengthy terms and conditions that few have the time to read
  • provide products and services that are right for their customers
  • focus on the real and diverse needs of their customers, including those in vulnerable circumstances, at every stage and in each interaction

The new rules will further require firms to focus on supporting and empowering their customers, enabling them to make sound financial decisions and avoid foreseeable harm at every stage of their relationship. Firms will have to communicate their service(s) to consumers in a manner that is easier to understand, tailor their product(s) and service(s) to ensure they meet their consumers expectations and provide satisfactory customer support and assistance when and where needed.

But it doesn’t stop there. The Consumer Duty’s responsibilities extend to FCA authorisations, a firm’s financial promotions and vulnerable customer management. The latter, a topic that started in February 2015 as the FCA’s OP8, has now become an FCA Rule as part of PS22/9, requiring firms to “focus on the real and diverse needs of their customers, including those in vulnerable circumstances, at every stage and in each interaction”.

Under PS22/9, firms were given 12 months to implement these new rules on all their existing as well as new products and services. An additional extension of 12 months has been given to closed book products and services, in order for firms to have adequate time to upgrade and update these older products and services in line with the new standards. Please find below a list of the deadlines associated with the FCA’s new Consumer Duty rules:

  • October 2022 – implementation plans and oversight of delivery agreed by boards
  • April 2023 – product manufacturers to share key information with distributors three months ahead of the implementation deadline
  • 31 July 2023 – deadline for the implementation of the new rules for new and existing products or services that are open to sale or renewal
  • 31 July 2024 – deadline for the implementation of the new rules for closed book products or services

A New Consumer Duty – How can Complyport Help

Being at the forefront of compliance and regulation, and in particular having consulted and trained the industry in concepts such as treating customers fairly, advertising and promotions and vulnerable customer management for many years, Complyport can assist firms in meeting their responsibilities under the FCA’s Consumer Duty requirements. Please find below a list of services we can undertake to assist your firm.

High level Consumer Duty Readiness Report

Using our on-line assessment tool, Complyport will undertake a review of your firm and provide a report of where it is with its Vulnerable Customer Management (“VCM”) and Consumer Duty implementation.

Within this review, we will:

  • Assess work undertaken so far, versus the FCA’s expectations,
  • Establish the senior management and policy framework that controls VCM and Consumer Duty, and
  • Identify high level areas for development.

PS22/9 – A new Consumer Duty Impact Assessment

Complyport can undertake a Consumer Duty Impact Assessment (CDIA). Following this review, we will provide a report that will act as a roadmap, outlining what needs to be completed and by when to ensure compliance with the new rules.

Our CDIA is an intensive gap analysis of your firm that will:

  • Examine the firm’s Vulnerable Customer Management,
  • Assess the Consumer Duty rule readiness,
  • Review Senior Management Responsibilities under the new rules,
  • Identify how the firm has or will make it easier for its customers to switch or cancel products,
  • Consider how customers interact with the firm,
  • Review the firm’s financial promotions scope, policies and procedures, and
  • Outline the training the firm may require.

Ongoing support

At Complyport, we can also provide firms with support now, and on an ongoing basis, to ensure full compliance with PS22/9. Our ongoing support services include:

  • Policy review and authoring – Review and recommend changes or author policies in respect of VCM and Consumer Duty,
  • SM&CR advice – Assisting a firm to embed VCM and Consumer Duty into its SM&CR programme,
  • Advice and support by telephone and email,
  • Reviews of new product offerings,
  • Reviews of financial promotions,
  • Financial Crime and Forensics Helpdesk.

Interested in seeing how we can help you with PS22/9 – A New Consumer Duty?

Please email Jan Hagen via or fill our free consultation form and a member of our team will get in contact for a personalised quote:

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