Pensions - Articles - 39 key questions firms should answer on new Consumer Duty

 “The final rules are out and anyone who still thinks of the new Consumer Duty as a tick-box exercise does so at their own peril.

 “Despite pushing back the deadline for full compliance, the first deadline is less than 3 months away when, by 31 October, the Boards or equivalent management bodies of all firms must have an implementation plan in place. They should also have appointed a Duty ‘champion’ by this date and while the governance structures may vary, this includes adviser firms of all sizes. All firms will need to set aside substantial time to study the detailed rules and guidance and to interpret what they mean for their business.

 “One means we’d recommend of gaining an early insight into the extent and nature of required changes is to carry out an informal ‘self-assessment’ based on the ‘key questions for firms’ sections in the Final Guidance.

 “The FCA describes these as examples of the type of questions firms can expect the FCA to ask them. They also expect the Duty champion to be using these to guide discussions with their firm’s Board or equivalent governance body.

 “There are 39 examples in total, many with two related questions, and while not all will be relevant to advisers, they’ll give firms an initial sense check of what needs covered in their implementation plans.”