CONSUMER DUTY CORNER
One of the main challenges of the consumer duty is ensuring you have the right data/MI to evidence and monitor customer outcomes. The FCA can only view the extent of your compliance through the documentation you provide, so it is all about showing how and why you have reached decisions and also demonstrating that you are meeting the 4 outcomes and evidencing and monitoring those outcomes.
There are three components from a systems and processes perspective:
• obtain the data you need to assess whether the outcomes your customers are experiencing are consistent with your obligations under the consumer duty.
• assess and analyse this data, to determine whether customers are not getting good outcomes, and any incidence of customer harm.
• remediation of any instances of customer harm identified through monitoring and testing; prevent such harm occurring in the future.
In any data strategy, you need to ensure that you gain engagement at Board level. In order to do this, you need to engage the Board throughout the process, provide regular progress updates and seek input on key issues.
Under consumer duty, the FCA has an expectation that firms will seek greater insights into the needs and motivation of customers – they expect greater use of qualitative data and a greater focus on customer behaviours.
What will the FCA expect?
• Sufficient volume and frequency of reporting
• Information is being considered and acted upon – issues remediated
• Appropriate data is provided to the Board
• Minutes of meetings demonstrating discussion and debate
• Effective information sharing with commercial partners
PIMFA Consumer Duty Microsite
Visit our microsite to access key information to help your firm prepare for Consumer Duty, including:
• 10 things you need to know
• Four outcomes
• Key actions
• Join our Working group
• Useful resources
PIMFA Index Series Questionnaire
PIMFA would like to gain a deeper understanding of how your firm is using the PIMFA Index Series, so we have constructed a brief questionnaire, featuring mainly multiple-choice responses, which should take no more than 5-7minutes to complete.
To access the survey, simply click here or scan the QR code below using your mobile device.
Your response is important to us and we very much appreciate the time taken to provide this information.
D& I Awards
Submit your free entry by 5 July
Share your story and inspire others!
There is still plenty of time to get started on your entry. Our expert judges look forward to reading your success stories again this year.
FCA’s Defined Benefit Advice Assessment Tool (DBAAT) options for training
The FCA has recently updated the Defined Benefit Advice Assessment Tool (DBAAT). The updated DBAAT includes a section on assessing abridged advice and contingent charging. Moreover, the information collection, suitability and disclosures sections have been updated to reflect the changes made in PS20/6 – Regulator Assessment: Qualifying Regulatory Provisions
FCA have reached out to PIMFA and are offering direct training on the use of the DBAAT for firms which wish to use this tool. Firms interested in attending a session should contact
Simon HarringtonThe right to use the DBAAT is subject to the FCA terms of DBAAT Licence Agreement, and the FCA recommend that firms use the tool to assess their past advice. The DBAAT sets out the key factors to consider when checking the suitability of advice and disclosure, and allows firms to understand what is expected.
Find out more and access the DBAAT on the FCA’s WEBSITE.
DWP report on the review of the pension transfers
The Department for Work and Pensions (DWP) has published a report on the review of the Occupational and Personal Pension Schemes (Conditions for Transfers) Regulations 2021 which sought to protect UK pensions savers from transfer scams.
The report shows that 94% of pension transfers were completed under condition 1 or condition 2 where no scam indicators (red or amber flags) were detected. 5% of transfers were completed outside of the regulations either through a contractual or discretionary transfer. One percent of total transfers were completed with a red or amber flag present. The report also finds that some providers were processing close to 99% of their transfers through condition 1 or 2, where no flags were present, whilst others were processing less than 20% this way.
Average ceding days for a transfer have increased by 4% from 13.4 days in 2021 to 14.0 days in 2022. The average ceding days for a simple transfer has similarly increased by 6% in 2022 compared to 2021.
We are aware that some firms have experienced a slower rate of pension transfer because of the regulations and would like to monitor whether or not this persists as the regulations continue to bed down. Please speak to Simon Harrington should you have any experiences of delays that you would like to share.
Thursday 29 June 2023 15:00 - 16:00
In this month's Operations Forum, we have three presentations:
• Charlie Pugh, Senior Business Change Manager, UK Product Management at Euroclear will be giving an update on Euroclear, CREST and their development plans;
• 'Consumer Duty - what does the future hold?' - Worksmart's Market Engagement Director Nic Dent and Business Development Manager Emma Howell discuss:
- Essentials for CD readiness for 31 July (what are the 'must haves' and what are the 'nice to haves');
- What are the practical challenges?; Looking ahead over the next - 6 - 12 months: what do firms need to focus on? How are they going to embed CD to make it BAU? How are they going to prepare for the Board attestations?
• New PIMFA Working Groups - a round-up of new Working Groups and their recent activities from Kevin Sloane
If you would like to join the Operations Forum, please contact Heidi Bryant
Access the DWP report of the regulation review HERE PIMFA Operations Forum - WebinarPIMFA/ Clyde & Co HR Survey
Initially launched earlier this year, this survey is looking to benchmark member firms’ approaches to maternity and paternity benefits across our industry.
Whilst we thank those who have taken the time to complete it, the survey remains very much open and we are keen to get more input from other firms to help get a more comprehensive picture.
The HR Survey is completely anonymous and takes only 5 minutes to complete. If you would prefer, you may also send details of your scheme details directly to Nyan San Lwin
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