The UK Financial Conduct Authority’s (“FCA”) new Consumer Duty, set to come into force on 31 July 2023, has been described by the FCA as a “paradigm shift,”1 a “watershed moment,”2 and as “raising the bar”3 for regulated firms. Yet, as the impending July deadline looms, many firms remain remarkably sanguine. According to research from Aviva released at the end of March, 84% of financial advisers consider the Consumer Duty to be just a “re-branded TCF” (with reference to the FCA’s treating customers fairly initiative),4 59% have yet to start preparing, and a particularly brave 17% have no concerns about the Duty at all.
Firms ignore the issue at their own peril. Therese Chambers, the FCA’s Director of Consumer Investments, has explicitly cautioned firms against treating the Duty as simply a “re-expression of treating customers fairly”5 and, given her new role as Executive Director of Enforcement, that is a statement the industry should take particularly seriously. This article will make the case that, far from being a rebrand, the Consumer Duty marks a fundamental transformation in the FCA’s standards, expectations and regulatory approach as a whole.
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