FCA identifies five key areas ahead of closed books Consumer Duty deadline

The Financial Conduct Authority expects firms to address key fair value challenges connected to goneaway customers, data gaps, vested rights and outcomes ahead of its looming Consumer Duty deadline for closed books.

While the deadline for implementation of the regulator’s Consumer Duty passed in July 2023 for active products, closed books have until 31 July 2024.

Participating in a webinar organised by Fairer Finance earlier this week, Graeme Reynolds, the FCA’s director of competition, explained closed products and services were given the additional year to comply due to challenges in these products in the form of goneaway customers, data gaps, vested rights and fair value.

Five key themes

Consequently, he identified five key themes in areas that firms should already be considering.

These include:

Reynolds added this is because some closed book products may be particularly prone to poor value.

He cited the example of customers in legacy products where they may pay higher charges than they would for other products where firms are competing for new business.

Fundamentals are similar

But Reynolds maintained he thought the fundamentals for fair value in most cases are little different for closed products as for open products.

“Firms should be able to assess and be able to demonstrate that closed products provide fair value to the customers,” Reynolds said.

“They should ask where prices are different to open products, why is that the case? What is the explanation from a fair value perspective?

“We expect firms to ensure they’re on track to comply with the deadline for closed book products and services.

“And of course, any firm struggling to meet the closed book deadline should very much get in touch with us to explain and help with discussion.”

 

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