The three-month extension for financial services firms to implement the FCA’s new Consumer Duty requirements is something of a double-edged sword. While extra time has been welcomed by the industry, it may have overshadowed a more pressing part of the announcement – the October 2022 deadline.
Firms now have just three months for their boards or managing bodies to sign off their implementation plans. The position here is clear: although there is more time to action, there is not more time for planning. The FCA will be scrutinising board decisions later this year.
This will require clear roadmaps to show how they will achieve this fundamental shift in culture across financial services organisations – moving from a mindset of preventing poor conduct, to proactively prioritising good outcomes for customers.
With the cost-of-living crisis tightening its grip, the FCA is likely to use the duty to ensure firms are really delivering.