The New Consumer Duty & The Requirements for Firms

• We have delivered workshops on Treating Customers Fairly and Conduct Risk for almost 10 years and have seen how the rules have changed and how firms have successfully adapted to them. We are also well aware of how FCA expectations and good practices have changed.
• We have served clients of all shapes and sizes in the financial sector and are fully aware of the obligations of a regulated firm and what is expected from them by the regulator.
• We have been delivering training for over 20 years and this is one of our core competencies. We are certain we know the topic as well as anyone in the marketplace
• Your course director has worked as both a regulator and in training regulatory requirements across wholesale and retail financial firms. He will pass on past experiences to enhance the workshop and help bring it to life
• We do not employ All our trainers are highly experienced professionals with relevant vocational experience in the real world
• Our case studies enhance the learning points and are often found to be essential in truly understanding the requirements and growing the skills to apply them
• We are always judged by our results, which speak for themselves and the feedback received from previous delegates has always been excellent.

• To understand the FCA’s new rules and requirements and how we got here
• To recognise the application of the new Principle and Conduct Rule and where current arrangements continue
• To consider good practice / avoid poor practices
• To consider the new rule requirements through each stage of the product lifecycle, and the client lifecycle too
• To be able to articulate the three cross-cutting rules and the four consumer outcomes and how they link to the six treating customers fairly outcomes (TCF)
• To link change to senior manager accountability under SMCR
• To begin formulating an action plan to identify and address relevant areas of need

CONTENT SUBJECT TO LAST MINUTE CHANGES BASED ON FINALISING OF THE FCA’S NEW RULES

Session 1: Where we were – to where we are

• Current timescales and expectations – the road to both deadlines
• Treating Customers Fairly (TCF) and Conduct Risk
• Alignment with SMCR
• Iterative frameworks and pre-implementation regulatory review
• Changes to the Conduct Rules and COCON

Session 2: The Consumer Principle / Principles 6 and 7

• Principle 12 – The Consumer Principle
• Mindset, culture and data in place to deliver the aims of the new Principle 12
• FCA Speeches and Commentary – 2022
• Gap filling – working towards a set goal

Session 3: Consumer Duty Cross-Cutting Rules

• Amplifying the Consumer Principle
• Three rules:
  • Firms must act in good faith towards retail customers.
  • Firms must avoid foreseeable harm to retail customers.
  • Firms must enable and support retail customers to pursue their financial objectives.
• Defining and understanding regulatory expectation

Discussion Exercise – Areas of our business impacted / prioritised

Session 4: The Four Outcomes

• Focusing on retail customers
• Consumer Responsibility
• Product Oversight and Governance – back to the drawing board
• Pricing and accountability
• Communications – clear, fair and not misleading but supercharged
• Transforming “customer service” to “customer support” and the client lifecycle

Session 5: Other important elements

• Outsourcing the Consumer Duty – in short, not an option
• Vulnerable Customers
• No private right of action
• Impacts on T&C; Financial Promotions, Compliance Monitoring; Audit activity; Induction programmes; Employee handbooks or Codes of Conduct; and Breach Management
• IT Programme management – enhanced MI and reporting
• Evolution or revolution?
• Non-handbook guidance

Case studies: TBC as industry commentary develops

Course Wrap-up

• Summary
• Questions
• Open forum

The consumer duty training course provides an analysis of the new rules and their impact.  We look at the key requirements and changes, but in the context of how we got here, what they build on, what the gaps were and why they needed to be addressed.

We then focus on the rules and their practical implications and application.  What do we need to do?  What needs to change?  What are the pitfalls and what are our options?

The rules impact a huge amount of what we do, from the senior leadership teams to the shop floor and to be ready to meet both deadlines, we should understand and map the challenges as soon as we are able.  This consumer duty training course provides essential support to your implementation activity and control framework oversight.