It is good to see that a new 'normal' is beginning to emerge. The Government is continuing its efforts to ensure that essential financial services are maintained with many in the sector being deemed to be key workers. Firms are planning what changes will be needed, for example to maintain socila distancing - fewer people in the office full time and continued use of technology to replace some face to face meetings. Many will have considered the lessons learned from recent events in terms of their business continuity plan. 

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

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

By now firms will understand their level of compliance with IDD requirements and know that it is not a tick box exercise. It remains crucial to involve all business areas in periodically reviewing the implementation of the requirements, such as customers’ demands and needs, product governance and disclosure. 

Firms will continue to keep a watching brief as more rules and guidelines from EIOPA and the FCA emerge. 

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'. Each should have clarity on accountability across senior management with their conduct rules training having been completed. 

The FCA have deferred the extension of the regime for certification until March 2021 but for many firms the first quarter of the year is their busiest time so they arre sticking with plans to assess their staff across a range of knowledge, skills and behaviour so that certificates can be issued in time for the end of the year. 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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