With staff back from summer leave and the Consumer Duty Policy Statement published at the end of July, the key question firms are asking is what deadlines do their teams need to work to?
Below you will find the 4 key Consumer Duty dates and key steps at each point.
31 October 2022
By this date, your firm needs to have an implementation plan in place. The board needs to have reviewed the plan and signed it off as being appropriately targetted, robust and deliverable. The plan dictates the work that the firm will undertake and should set out timelines and governance.
Key tasks here include ensuring the board is well-briefed on Consumer Duty and of course ensuring that a considered implementation plan is put before them, allowing enough time for the required scrutiny.
30 April 2023
If your firm is classed as a Manufacturer - for example, if you create products and services - you need to have met the outcome rules for open products in order that you can share the details with your Distributors. This is to ensure that the Distributors can be compliant ahead of the main, July 2023 deadline (below).
An essential part of preparation here is reviewing a rules matrix, detailing the outcomes rules, against your open products. This will provide you with a clear list of where steps need to be taken and where you may already meet the requirement.
We would recommend starting this work shortly after 31 October, to enable enough time to meet the deadline.
Also, if your products are subject to the new High Risk Investments rules - which have December 2022 and February 2023 deadlines - you may want to undertake both sets of work at the same time.
31 July 2023
This is the main implementation deadline. By this point, the firm must be fully compliant with the Consumer Duty Rule. The only exception to this is for products that are no longer open to investment, where the July 2024 deadline applies.
Again we would recommend using a rules matrix as a key tool in identifying the streams of work you will need to undertake to become compliant with the new Duty. This gap analysis work will provide you with a clear set of tasks to undertake.
We would not recommend waiting until after the April deadline to begin this work given the level of change that may be required, and so would recommend this gets started as soon as is feasible after the October deadline.
31 July 2024
The final deadline applies where your firm has closed products and services. Essentially, it allows an additional year to reach compliance with the Duty for these products. You do not of course need to take the full year if you do not need it, but it is a helpful way to allow firms to focus on the live products and services first.
The rules for closed products differ, so your rules matrix needs to factor this in where you have closed products. However, the key task remains: undertake a gap analysis between the rules matrix and each of your closed products and services to create your task list.
Next steps?
The implementation plan and board briefing should be the first area of focus, followed by the establishment of your rules matrix, ready for each stage of the gap analysis. As the April deadline will come up fast and the level of change that may be needed to meet the June deadline is significant, we recommend both sets of work streams start in November.
How we are helping
Adempi is on hand to help with Consumer Duty, whether that's providing you with tools, helping you work through your gap analysis, or updating your policies. For details, get in touch at contact@adempi.co.uk.
We're also conducting training for boards to provide an overview of the Consumer Duty and their obligations as senior managers, and will shortly have training for the teams implementing the regulatory change. Our e-Learning modules for staff will also be updated in 2023 to reflect the changes.
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