All firms are expected to complete an annual consumer duty board report.  The report serves as a comprehensive overview of the firm’s adherence to the Consumer Duty and is proportional based on business size and risk, with large firms requiring more in-depth reports compared with typically a 1-2 page report for a small broker with lower risks. 

'A firm must act to deliver good outcomes for retail customers' - is the overreaching consumer principle.  The Consumer Duty is a step up from exisitng TCF principles.  Is it new?  Not entirely, some of requirements of the consumer duty have been in the handbook for some time in some form or another. It will mean taking a more in-depth look at your business to ensure you always deliver on ‘good consumer outcomes’.  See below for a condensed version of the Consumer Duty for mortgage brokers:

A number of interesting snippets were included in this month's email from the regulator. However, their brevity within quite a packed email makes them likely to be overlooked, so we thought it useful to extract and repeat here.

We briefly covered customer vulnerability last year; explain how firms should have systems in place to recognise vulnerability, and then a process to ensure the vulnerable customer is treated fairly.  The subject has been raised again in light of the current conditions and we have been asked by a number of brokers ‘Are all customers now considered vulnerable?’

Many financial services workers who previously worked in an office environment have been confined to working from home over the last couple of months. This has brought a range of advantages and disadvantages but it’s possible that such working practices may have to continue to ensure social distancing even as restrictions are lifted. Additionally some firms may continue to allow staff to work from home in the longer term. This does create potential risks that may not have existed or were easily managed within an office location.

With a little over a month to go before the Senior Managers & Certification Regime comes in, use the questionnaire below to find out what you need to be doing in order to get ready in time. 

These are some of the most common errors picked up from file checks over the last 12 months. Easily avoided with the correct tools and time spent when completing paperwork.

The Senior Managers and Certification Regime (SM&CR) introduces changes on how the FCA will regulate people in financial services, it replaces the existing Approved Persons Regime, and will be in place by the 9^th December 2019.  The SM&CR will apply to all FCA solo-regulated firms authorised under Financial Services and Markets Act, it will not apply to Appointed Representatives.

The deadline to implement the changes under the Insurance Distribution Directive is the 1^st October 2018.  This replaces the Insurance Mediation Directive which came into effect on the 14^th January 2005.  If you are not yet up to speed with the changes we have summarised the key changes to make for brokers below.

The FCA have made a change to the fee tariff data reported on section J of the Gabriel return.   Some firms are not aware that the change should be reported on the 2018 annual return.