In a pivotal move on November 8, 2023, the Financial Conduct Authority (FCA) issued a yet another "Dear CEO" letter this time addressed to wealth managers and stockbrokers, outlining critical Consumer Duty driven directives and expectations. This letter comes at a crucial juncture, signalling a new, proactive ‘targeted, intrusive and assertive’ FCA stance to supervision and oversight. Given the Consumer Duty is now demanding firms take a holistic and data driven approach to evidencing constructive conduct, competence and culture, we are already witnessing financial advice firms receiving unsolicited information requests to gain evidence for;
While may will view St. James's Place's (SJP) decision to cancel exit fees in response to the Financial Conduct Authority's (FCA) Consumer Duty as long overdue, it's essential to view this move more critically. If we look under a few rocks, there are some interesting perspectives we have come up with as to why SJP (and other industry monoliths) may have made this decision:
The latest FCA review of firm’s consumer duty implementation process has highlighted key concerns across a well-used regulatory tool that of proof of value (POV). Given that evidencing fair value across the Duty’s second outcome is highly subjective this was always going to be a big challenge for adviser firms.
The FCA's 2023/2024 business plan outlines three key priorities: protecting consumers, ensuring market integrity, and promoting competition. Let's take a closer look at each of these priorities.
So, the final rules are here and not much has really changed other than the implementation period has been extended slight for live business to July 31st, 2023, and closed book business has until 31st July 2024. Plus (wait for it) firms need to be up and running on their implementation by October ’22! Although any extension is welcome, it’s not long enough in my opinion given the ramifications this all-encompassing regulatory directive brings. Think Operational Resilience which has an implementation and transitional period totalling four years!
As we enter a new year, it provides us with an opportunity to review the past years activities and look ahead at what is to come. Indeed January is named after the Roman god Janus, who had two faces so he could see the past and future. What Janus may have told us from a regulatory perxpective.is the FCA are 'one one' with their future vision and learning from the past when it comes to firms regulation data and compliance analytics.