Target Newsletter - Issue 186 February 2023

Paradigm Compliance Update

Consumer Duty Implementation Plans: Publication of Multi-Firm Reviews

Our Summary of the FCA’s Key findings Governance and oversight Good Practice • Many firms have developed robust governance frameworks for their implementation work, with clear accountability for delivery and board oversight. • The FCA identified that the plan had been scrutinised and challenged by firms’ boards, executives and their audit and risk functions. For example, through questioning resource requirements and interaction with other ongoing project work. In one example, a firm is delivering one-to-one deep dive sessions with board members on plan deliverables. • Most firms have appointed a Consumer Duty champion at an appropriate level to ensure that the Duty is discussed in a meaningful way. The FCA identified an example where a firm with a large group structure has appointed two champions to reflect the diversity of its different regulated entities. The FCA will continue to engage with firms and a survey will be sent out shortly to a sample of small firms to help the FCA understand what progress is being made in that sector. Further, targeted engagement of small firms will also be undertaken by the FCA. In addition, some firms will already have received a follow up letter “Implementing the Consumer Duty in the Consumer Investments sector”, which is a reminder of the FCA’s expectation on firms, and you will also have been made aware of the regulator’s upcoming in person events on Consumer Duty. Finally, Paradigm will also continue to produce “On Film” events to support firms.

Graeme Stewart Head of Consultancy Paradigm Consulting

Introduction

The FCA has recently published their findings following a multi-firm review of Consumer Duty implementation plans. They have reviewed the implementation plans of larger “fixed” firms who have a dedicated supervision team at the FCA. They did this to better understand firms’ approach to embedding Consumer Duty within their business. • The firms’ approach to governance and arrangements for ongoing oversight of their implementation plans. • The deliverability of firms’ plans. • Firms’ culture and people strategies to ensure that their business is focused on delivering good outcomes for consumers PARADIGM COMMENT Paradigm believes that firms, and in particular the SMF16, will want to read this update from the FCA as you and your firm continue to develop and progress the work contained within your Consumer Duty implementation plan. and that all staff understand their responsibilities under the Duty. They considered a range of different factors including:

8 TARGET NEWSLETTER