Date(s) - 26/10/2022
10:00 am - 12:00 pm
Join us to look at the consumer duty regulations through a T&C lens and discover why 90% of delegates confirm they will have to make changes to their T&C schemes.
Delegates have used phrases including ‘very useful session,’ ‘insightful,’ and ‘great session’ to describe their experience of attending.
Introduction and Background
The FCA has published their policy statement PS22/9 on the new Consumer Duty. The changes will affect your T&C schemes. A New Consumer Duty contains feedback to their second consultation CP21/36. The policy statement paves the way for a new Consumer Principle for retail firms replacing Principles 6 (TCF) and 7 and placing a greater layer of requirements upon firms. New cross cutting rules and evidential based outcomes will challenge firms to demonstrate that firms have put customers at the heart of what they do and have achieved good consumer outcomes.
This online event is focused on how this will affect the approaches you take within your T&C schemes to ensure that they play their part in achieving what firms must consider doing to meet regulatory expectations. As it stated within the CP21/36
Firms extend their focus beyond ensuring narrow compliance with specific rules, to also focus on delivering good outcomes for customers
Amongst other things you may need to review
- The structure and content of your T&C Procedures
- The training needed for new starts
- The way your advisers and support staff interact with customers
- The standards you need to determine competence
- The way you conduct FIT and proper assessments under the Certification Regime
- How your T&C MI contributes to the effective governance of the new consumer duty
- Whether you need to introduce T&C approaches to other business areas
Policy Statement 22/9 sets out how the FCA expects firms to achieve good outcomes for customers and in the process raise standards of protection and improve how financial services markets operate.
The FCA requires firms to have an implementation plan in place by the end of October 2022 which creates a route map demonstrating how they will comply with the new Consumer Duty.
In order to be successful firms will be looking to perform a gap analysis to identify where they fall short of the expected requirements. It will not be wise to assume that all your existing approaches will stand up in the desired future state.
Your T&C scheme, one of you people management policies, plays an important role. A case could be made that it holds one of the keys to your success. Positioning your T&C scheme or schemes as a true business enabler to deliver good customer outcomes may require you to change some aspects of what you do.
Failing to align your T&C Scheme with the ‘direction of travel’ will mean that firms will struggle to deliver the new Consumer Duty.
What you get out of attending
- An understanding of the relevant rules within consumer duty from a T&C perspective
- Reassurance of how your current approaches fit within the FCA requirements
- Identify any areas where you may need to make changes and why
- Know what to include in your implementation plan
What you will not get out of attending
- Focus on aspects of consumer duty that are not relevant to you
- A sense of foreboding that your T&C approach is wrong
- A push from a consultancy to try and promote their services
- A wasted 2 hours
- To understand the key elements of the new consumer duty through a T&C lens
- To construct a customer journey and identify the touch points that will need to be addressed
- To analyse the key skills and changes that are needed to support a consumer outcome approach rather than one that is compliance driven
- To critique the management information needed to evidence a consumer outcome approach
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