SUMMER/AUTUMN JOURNAL | 2023
HOW TO EMBED CONSUMER DUTY IN 7 PRACTICAL STEPS
PIMFA.CO.UK
As the dust settles after the July deadline for Consumer Duty (CD) compliance, the overwhelming feedback we’ve had from clients and other contacts is that, with huge collective effort, and to much relief, their CD change programmes have delivered on time.
The hard work has paid off. They are compliant. But with a big caveat that there is a lot of work still to be done: Outputs and procedures developed by CD project teams must be dropped into ‘business as usual’. Some have set up special oversight committees to supervise closure of programme workstreams. Many firms have had to scale back their plans to get the ‘basics’ over the line. They now need to execute ‘Day 2’ plans to deliver outstanding requirements. There is the ongoing challenge of embedding CD into day-to-day culture. So how do you embed CD into your organisation’s culture and practices? We advise our clients to break down their next steps into 7 key areas:
1) FORMALISED PLANS AND RESOURCE ALLOCATION With the deadline behind us, competition for project resource will be fiercer, so CD must be kept centre stage, with a clear roadmap and allocated budget and resources. To maintain urgency, some organisations have arranged a CD compliance audit to shine a light on remaining shortcomings. Don’t forget that there is a further implementation deadline of July 2024 for legacy products. You may have a new set of requirements for these, and your plans should lean heavily on the frameworks already in place for live products.
9
