Now that the Consumer Duty is in force for all on-sale products and services, firms should now be gathering evidence of the outcomes being received by retail customers, and looking ahead to the first Board certification exercise next summer. In order to aid firms in meeting these objectives and to help firms have confidence that they have had regard to the full range of considerations needed to implement the Consumer Duty, we have developed our Pathfinder Tool.
The Pathfinder Tool includes a key checklist tool that will allow firms to work through whether they have addressed all relevant aspects of the Duty, and to help identify any required improvements to address any gaps in coverage of the Duty as a whole. Alongside this core checklist, the Pathfinder Tool includes guidance notes on the different aspects of the Duty, and indicates those interpretative points where firms may need external advice which is specific to their organisation’s set-up, products and services. The Pathfinder Tool has been produced on the basis of our experience advising a number of firms across different areas of the market on the implementation of the Consumer Duty.
The Pathfinder Tool is intended to provide a more practical guide to implementation, by including reference to each of the underlying rules in PRIN 2A and COCON (which introduce the Consumer Duty into the FCA Handbook) as part of the checklist. This means that firms can use the Pathfinder Tool to help evidence compliance with all relevant aspects of the Consumer Duty.
If you are interested in our Pathfinder Tool, please register on our website by searching for “The FCA’s new Consumer Duty: Is your firm ready?” and clicking Register at the bottom of the page.