Consumer Duty rules are subject to considerable interpretation, which is wholly reasonable, writes David Ogden. Here he explores what advisers should concentrate on to make sure their processes are aligned with regulatory expectations
Although the full implementation of the FCA's new Consumer Duty has been delayed until July 2023, it seems clear the regulator's latest attempt to put the best interests and outcomes for customers at the heart of firms' processes keeps the subject right at the top of its priorities. Is there a reason to be confident this initiative will succeed where Principles, Treating Customers Fairly, the Responsibilities of Providers and Distributors, PROD, the Senior Managers Regime and numerous previous enforcement actions have demonstrably failed to achieve cultural change? It is hard to conclude...
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