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Nick Bayley, managing director within Kroll's Financial Services Compliance and Regulation practice comments:
“This is no simple re-badging of the longstanding TCF (Treating Customers Fairly) rules. Firms’ current obligations to their customers are often seen as rather passive “A firm must pay due regard to the interests of its customers…(Principle 6), whereas the new consumer principle to ‘act to deliver good outcomes for retail clients’ (Principle 12) is a much more active responsibility.”
“Firms will undoubtedly welcome the FCA taking on board their feedback and extending the implementation period for new and existing products by an extra three months to July 2023. But firms should still not underestimate the amount of work that may be necessary to perform their gap analysis and then implement this significant change.”
“The Regulator clearly believes that many firms do not sufficiently consider their retail customers’ interests and is placing the new responsibility for achieving good customer outcomes fairly and squarely on the shoulders of the firms’ governing bodies.”
