On 7 April 2020, set against a backdrop of unprecedented challenge, the FCA released its Business Plan for 2020/21. From a retail consumer perspective the FCA notes its main priorities are to ensure that financial services businesses give them the support they need and that customers don’t fall for scams.

Key actions the FCA has taken recently include:

  • Proposing guidance around a range of temporary measures to support users of consumer credit products
  • Setting out new guidance for mortgage providers on payment holidays for consumers in financial difficulties
  • Clarifying expectations for general insurance providers and providing information for consumers to help them understand what to expect from their insurers

As these measures move forward over the coming period, firms should keep their processes under regular review. Whilst fair customer treatment is of course paramount, firms will need to both flex their systems and ensure they are consistent, for example:

  • Having clear and consistent regular governance meetings and discussions as the crisis develops – ensuring that retail customer outcomes are fed through in management information and reporting
  • Regularly reviewing response plans so that customer feedback and evolving areas of focus can be factored in
  • Ensuring a consistent protocol is in place (with appropriate guidance) for evidencing key decisions on customer outcomes and how and when to escalate matters. This is particularly important in terms of accountability regimes such as the SM&CR
  • Being clear, regular, consistent and joined-up with public and customer communications
  • Keeping “fairness” under review, for example not recovering when it is actually in the customer’s best interests could create unfair outcomes and detriment over time.