How Evelyn Partners have approached Consumer Duty

On the 27th July 2022 the FCA published final rules on Consumer Duty, referencing the need for Firms to act to deliver good outcomes for retail customers which includes requirements for both manufacturers and distributors. Under the new Consumer Duty, the FCA has set out three rules: (1) Acting in good faith, (2) Avoiding causing foreseeable harm and (3) Enabling and supporting customers to pursue their financial objectives. These are supported by the four Consumer Duty outcomes: Products and Services, Price and Value, Consumer Understanding and Consumer Support.

Our approach to Consumer Duty has been to review all of the requirements and guidance, take examples of what good looks like that the FCA has provided, and through a series of in-depth workshops for each of our product areas ask ourselves, "are we doing this well enough?". From those workshops and feedback sessions we developed a detailed project plan, with areas where we felt our existing activities were fit for purpose, areas where improvement was required and areas which required building new processes, MI and frameworks.

The key areas of work have included (amongst many other things):

• Developing a new client feedback programme with Consumer Duty related questions to obtain continuous feedback from our clients on their experiences.
• Assessing key client communications and high-risk communications and engaging an external provider to support a review to ensure client understanding is optimised.
• Developing the new product governance and fair value framework and assessing each of our products and services against these new frameworks, explained in more detail on this site.
• Developing new MI dashboards mapped against Consumer Duty outcomes so we can see trends in complaints, client file review outcomes, service and support provided to clients and other metrics, all through the Consumer Duty lens.
• Updating our governance framework to include a Consumer Duty champion, SMCR mapping, compulsory training, board reporting and attestation requirements, to ensure the governance supporting Consumer Duty is sufficiently robust .

Throughout the programme we have attended industry forums and events and collaborated with manufacturers, distributors and service providers we work with, to ensure our approach is consistent and fit for purpose.

We welcome any feedback you may have on the content of this site and for any further questions, please refer to your Evelyn Partners relationship manager.