At Broker Direct we have always looked to put the Consumer at the centre of everything we do and provide customers with good outcomes.  We are supportive of any regulatory changes designed to improve outcomes for customers such as ‘The Consumer Duty’.

Regulatory Overview

In July 2022 the FCA released their A new Consumer Duty Policy Statement which set the standards firms should give to customers and includes:

A New Consumer Principle (Principle 12) – A firm must act to deliver good outcomes for retail customers.

Three Cross Cutting Rules:

  • Acting in good faith – This is a standard of conduct characterised by honesty, fair and open dealing and consistency with the reasonable expectations of consumers.
  • Avoiding causing foreseeable harm – This means firms not causing harm to customers through their conduct, products or services and taking proactive steps to avoid it (where it is within the firm’s control to do so).
  • Enable and support customers to pursue their financial objectives – Consumers should be empowered to make choices for themselves and remain ultimately responsible for their decisions and actions.

Four Outcomes:

  1. The governance of products and services
  2. Price and value
  3. Consumer understanding, and
  4. Consumer support

The deadline for implementation of Consumer Duty is the 31st of July 2023 for all new and existing products that are currently available, or will be available to customers.

For further information on the Consumer Duty, please see the FCA’s  Consumer Duty homepage.

What We Have Done

To ensure we continue to put the Consumer at the centre of what we do and and to meet the Consumer Duty and regulatory requirements, we have:

  • Completed our initial annual product value reviews. This took place in Quarter 3 2022 under the Product Governance regulations.
  • Agreed at Board level a ‘Consumer Duty Plan’ and an ‘Implementation Plan’. The ‘Implementation Plan’ is an extensive gap analysis which covers ‘Product Governance’, ‘Price and Value’ ‘Consumer Understanding’, ‘Consumer Support’, ‘Monitoring’ and ‘TCF’, ‘Conduct’ and ‘Complaints’.
  • Reviewed and enhanced our internal management information and mapped it to the Four Outcomes.
  • Appointed a Consumer Duty Champion.
  • Delivered training to all staff on Consumer Duty.
  • Reviewed our established processes and procedures including:
    • Our vulnerable persons policy and procedures to ensure we are offering appropriate support to those in need
    • Our communication policy to ensure that not only are our communications (including policy documentation) signed off by our Head of Marketing and Compliance, but also a layperson to ensure the communication is clear to the intended audience.

If you have any feedback or questions on Broker Direct and the Consumer Duty, please email [email protected].