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Consumer duty implementation plan needs to be 'solid'


The implementation plan of the regulator’s new consumer duty needs to be solid and signed off in a timely manner, according to a number of SimplyBiz compliance experts.

In a video of the back of SimplyBiz’s consumer duty advice show, those in compliance and regulatory roles gave their key takeaways on dealing with the consumer duty. 

SimplyBiz head of business consultancy Karl Dines, said: “First of all, I would say make sure your implementation plan is really solid, overengineered and really focused on what you were doing to get the job done. 

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“Secondly, start working on the consumer duty now and don't leave it till the last minute because the regulator might pick up the phone and speak to you about it.”

Likewise, head of regulatory consultancy Jennifer Peaty, said management information is “imperative” but individuals need to get their “diaries out”.

“You've got 10 weeks, you need to have an implementation plan signed off by the board. You have to [know] who's gonna take responsibility for consumer duty and who else do you need to engage with. 

“We've all got busy diaries and there's going to be holidays in the diary as well so it's really important for firms to [understand] how we are going to do this.”

Good outcomes

SimplyBiz senior compliance policy manager Sandy McGregor, said the consumer duty outcome policy specifically is an area it has been looking into.

“It's something we've been talking about for probably a year plus and we've tried to create templates so that firms can - in advance of providing their advice -  make sure the customer understands the risks that are associated with the transaction.

“Everyone is in a much better position if consumers are empowered to understand what the advice actually is.”

Meanwhile, director of compliance policy Richard Nuttall, argued the best way a firm can evidence a good outcome is by having independent quality file assessments and KPIs to demonstrate it. 

“That will be the key big deliverable from a consumer duty, because that's what it's all about. 

“It's about ensuring that people have got the right products, the right solutions, and the right time to meet the needs.”

To watch the full interview, click on the image above.

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