Corterum Newsletter 2023

Corterum newsletter: November 2023

At Corterum, we want to keep you informed about the latest developments in the world of compliance.  Considering these changes may have an impact on your business, November’s Newsletter has a focus on Consumer Duty, to make sure you are aware of what’s happening.  

On the 1st of November, Nisha Arora (the Director of Cross Cutting Policy and Strategy at the FCA) presented a speech about the next steps involved in Consumer Duty.  The main takeaway of her message was that Consumer Duty is not a temporary, or one-off, measure.  Firms will need to prove that they are learning and improving continuously, while also being able to evidence their compliance in their annual board reporting.

Consumer Duty has now been in place since July this year, and Nisha advised that the FCA had already seen good practices being put in place and followed.  Some firms have simplified, or made more accessible, the language they use in their letters to their customers, while others have reviewed their fees with fair value in mind.  They are very happy with the approaches businesses have taken so far and want to fully embed Consumer Duty into the day-to-day practices of the industry.

Maintaining this forward momentum is now their priority.  They want everyone to recognise that this is not just simply an exercise in compliance, but as a change in the culture throughout the financial industry.  They want everyone to revisit their implementation plans and confirm not only that they’ve made the changes they have set out, but whether these changes go far enough.

If you would like further reading, you can view the full article here.

As part of our commitment in helping you adhere to the regulatory timelines, we also want to remind you that the Consumer Duty comes into force for CLOSED products at the end of July 2024.  This deadline coincides with the first annual requirement on the part of boards to review and approve an assessment as to whether the firm is delivering good outcomes for its customers under the Consumer Duty and any actions required as a result of the monitoring.

The board’s annual report, together with all underlying management information, must be made available to the FCA upon request.  Considering the Consumer Duty requires you to summarise, test, approve and review every product you offer, at all stages of its lifecycle, this may take you a substantial amount of time.  It may be best to start organising this if you have not done so already.

Corterum does offer a module for managing your Consumer Duty compliance efforts, so should you be looking for a new solution to record your data, or want a better system for generating the reports, look no further than what we can offer you.  Please get in touch and we’ll set up a demo, presenting how we can give you piece of mind with the efficient and easy to use Corterum platform.

The FCA has now published guidance for Crypto Firms who are looking to comply with the new marketing rules.  With crypto markets viewed as high-risk investments, the FCA is keen to help and provide guidance to these firms, so if they choose to comply with Consumer Duty, they can do so effectively and easily.

If you would like further reading, or to view the guidance, you can view the full article here.

How are you achieving your SM&CR compliance efforts?  If you would like an evaluation, then please take a look at our SM&CR Evaluation Questionnaire.  This user-friendly resource will help you assess your SM&CR practices, providing a useful report that will help you identify areas for improvement and ensure that your firm is in line with regulatory requirements.  Please follow the link above to access it.

Should you have any questions or require further clarification on any of the mentioned topics, please do not hesitate to get in touch.