On 6 April 2023, the FCA published a Dear CEO letter (dated 31 March 2023) intended to help firms whose primary business model is marketing and providing contracts for differences (CFDs), spread bets or rolling spot foreign exchange to retail customers, to help them implement and embed the Consumer Duty.

The letter sets out:

  • A reminder of the implementation timeline, key elements of the Duty and how it applies to firms in the CFD portfolio.
  • The FCA’s expectations for how firms should embed the Duty, including relevant examples of good and poor practice.
  • Feedback from the FCA’s recent review of firms’ implementation plans.
  • The FCA’s approach to supervising the Duty and planned next steps.

Annex 1 to the letter describes how the Duty applies to firms in the CFD provider portfolio. Annex 2 to the letter describes key things for CFD firms to consider. This covers governance of products and services, price and value, consumer understanding and communications and consumer support and service. The FCA has also added the letter to its supervisory correspondence page.