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The Consumer Duty deadlines
Hi. I’m Alistair McQueen at Aviva.
In this video I will look at the FCA’s Consumer Duty deadlines towards full implementation.
The Consumer Duty was finally born in July 2022. Initially, the FCA had suggested all changes should be implemented and all actors should be compliant by April 2023.
To its credit, the FCA listened to industry feedback which voiced concern that the desire to move at pace could compromise the quality of delivery. And to the FCA’s credit, the rush to April 2023 was replaced with a more considered timeline, with four noted deadlines.
The first deadline has passed. By 31 October 2022, all of us should have documented and approved our implementation plans, stating at a high level how we would progress towards Consumer Duty compliance.
Since the date of 31 October 2022, the FCA has had the authority to knock on any of our doors and ask to examine any of our implementation plans. If your door has not yet been knocked, you have been warned.
The second deadline is 30 April 2023.
By this date, manufacturers - such as Aviva - must make available to distributors - such as yourself - the conclusions of our “open” product assessments, with comment on each product’s target market, distribution strategy, and fair value conclusions.
By “open” products, we mean those that are open for sale or open for renewal.
This information is necessary to allow all distributors – such as yourself - to review if and how each product they use satisfies the expectations of the Consumer Duty. Is it a good product? Does it offer good value? Does it have good communications? Does it enjoy good service?
The third deadline is 31 July 2023.
This is a big one! By this date all “open” products and services – or, in very simple terms, those that are open for business – will be judged against the FCA’s Consumer Duty expectations. Can we evidence that we are delivering good open products and services, at good value, with good understanding, backed by good support?
And finally, 31 July 2024. By this date, all closed products and services will be judged against all elements of the Consumer Duty too.
By closed products we mean those that are no longer marketed or distributed to retail customers, nor are they open to renewal.
So, by 31 July 2024, the Consumer Duty will apply to all relevant activities in our market.
But this date of 31 July 2024 is not the end of the Consumer Duty story.
Complying with the Consumer Duty is not a “once and done” exercise. It is an ongoing way of being. Continual compliance with the Consumer Duty is our ticket to trade in our market.
So the compliance with the Consumer Duty will remain on our annual “things to do list”, from now on.