Signs are that it will be some time before we return to something resembling 'normal'. The Government is endeavouring to ensure that essential financial services are maintained with many in the sector being deemed to be key workers. Some firms are looking forward to consider how they will respond to the new normal; will we have fewer face to face meetings and are there lessons to learn from how the current working from arrangements impact on productivity? 

The FCA is the regulator of claims management companies (CMCs). There have been many firms in this sector who have chosen to cease trading rather than take on the new standards and rules. The survivors have the opportunity to become trusted providers of high quality, good value services that help customers pursue legitimate claims for redress. 

 

The advent of flexibility in pensions has caused some significant shifts in approach for providers and advisers. For the FCA the key is ensuring that consumers are given advice which is both accurate and comprehensible. One key area that we are finding firms needing to consider is how they ensure that they can demonstrate options are considered appropriately and kept under review. 

The IDD is a recast of the existing Insurance Mediation Directive and is designed to ensure a level playing field across all participants selling insurance products. 

Firms first need to understand their current level of compliance with IDD requirements. This is not a tick box exercise and will involve several areas of the business. It will be crucial to involve the business areas from the outset when carrying out the impact analysis of some of the requirements, such as customers’ demands and needs, POG and disclosure. 

Firms will also need to keep a watching brief on more rules and guidelines from EIOPA and the FCA as the regime takes shape. 

The FCA remain concerned about the scope for incentives to distort behaviour. We are seeing more questions during the application process around conflicts of interest than previously. Firms should be looking again at what incentives they have in place and considering whether rewards motivate behaviour that is in the clients’ best interests.  

All FCA regulated firms are now embedding the Regime into 'business as normal'. There should now be greater clarity on accountability across senior management with their conduct rules training having been completed. 

2020 sees the extension of the regime to a wider range of people as certification is rolled out. Many firms have plans in place to assess their staff across a range of knowledge, skills and behaviour so that certificates can be issued. Some may be struggling, there is still some time to get this right.  

The FCA are concerned that standards of conduct and customer communication are not yet sufficient. They're looking to ensure that all payment service providers and e-money issuers are clear and transparent and that the marketing and promotion of currency exchange transfer services with unachievable exchange rates or unsubstantiated claims ceases. 

The FCA’s aim is to increase consumer protection in the market and to ensure consumers are provided with the information they need to make an informed decision about the services that best meet their needs. 

 

The FCA continues to monitor firms within the consumer credit industry and one of their concerns remains the way in which creditworthiness is assessed. Good firms will regularly review their policies and processes in order to make any necessary changes. For example can staff clearly distinguish between credit risk and affordability risk in carrying out a creditworthiness/affordability assessment. 

 

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