9th April 2024: Consumer Duty Training

Course Overview 

In July 2022, the Financial Conduct Authority, or FCA, published a policy statement, with final rules, on its Consumer Duty initiative. This comprises a new principle, cross-cutting rules, and four outcomes for retail consumers.

The Consumer Duty will mean that consumers should receive communications they can understand products and services that meet their needs and offer fair value, and obtain the customer support they need, when they need it.

Clarity on the FCA’s expectations, and firms’ focus on what their customers need, should lead to more flexibility for firms to compete and innovate in the interests of consumers. With firms assessing how they are meeting their customers’ needs, the FCA will be able to quickly identify practices that do not deliver the right outcomes for consumers and take action before practices become entrenched as market norms.

Regulated firms will have to comply with the Consumer Duty from 31 July 2023, with a delayed implementation of 31 July 2024 for products that are closed or not being sold to new investors.

Learning Outcomes

By the end of the programme, participants will:

• Understand and explain the FCA Consumer Duty
• Articulate the changes required as a result of the Consumer Duty
• Explain the desired outcomes for consumers
• Describe how firms can begin to evidence their compliance with the Duty
• Appreciate how the Consumer Duty applies across different sectors

Training Outline 

Regulatory expectations – the role of Compliance Monitoring

• Aims of the Duty
• The Consumer Principle
• 3 cross-cutting rules
• 4 outcomes
• Impact on Conduct Rules

Monitoring Outcomes under the Consumer Duty

• What do the regulators expect?
• What might a monitoring programme look like?
• Focus on vulnerability

Senior Managers and the Consumer Duty

• Regulatory Expectations
• Supporting senior managers from the bottom up
• Building evidence of reasonable steps

Recognising differences

• Impact on retail banking
• Impact on consumer credit
• Impact on wealth and asset management
• Impact on insurance distribution
• Impact on mortgages

Industry Expert | Steve Fairclough

Steve began his financial services career in 1993 and has over 20 years practical training experience across a range of sectors and topics.  He is a former Head of Education for HSBC covering the UK and Europe, responsible for regulatory and financial crime related compliance learning.  His time at HSBC was during intense scrutiny from regulators and government functions during the bank’s Deferred Prosecution Agreement.  Other roles include leading the Monitoring and Testing programme for a UK Wealth Manager, and Senior Vice President responsible for Global Risk & Compliance training at a US-based bank.  He also worked in the Insurance Firms division at the Financial Conduct Authority (in the FSA days) where he was the divisional expert for the rules and outcomes required under the Training & Competence handbook.

The HSBC role, along with five years at Barclays in their Private Clients and Wealth functions, has seen Steve work with retail, commercial, wholesale and private banking channels.  Since leaving HSBC, Stephen has worked with the compliance, HR and operational teams of firms to enhance their regulatory understanding, as well as delivering content across private equity firms, investment houses, banks and wealth managers.  He regularly delivers core programmes for TISA and the Investment Association.

Steve is a former member of the Investment Management Association Training & Education Committee and won the Thomson Reuters award for “Most Effective Compliance Training at a Regulated Firm” in 2010.

Who Should Attend 

Relevant staff roles include Risk and Compliance, Operational Oversight and Management.