On 6 March 2019, the FCA published a letter it had sent to firms setting out the results of its review of credit card fees and charges.

The FCA reports that there are opportunities for firms to improve outcomes for their customers and take appropriate action where there are signs of actual or possible financial difficulties. Firms should consider whether their policies and procedures in relation to fees and charges result in fair consumer outcomes and are compliant with the rules and guidance provided in CONC 7.

The FCA gives the following examples:

  • What does your firm regard as signs of actual or possible financial difficulties? Are (multiple) fees and charges considered as one of those signs?
  • Does your firm flag on its systems those customers who are repeatedly incurring fees on their account?
  • What range of actions your firm takes when identifying a sign of actual or potential financial difficulty and are you satisfied they meet the requirements of CONC 7.3.4R?

The FCA expects senior managers to ensure the message in the letter reaches the relevant people in their organisation.