Consumer Duty is a thread that runs through almost every piece of work that we see come from the regulator, whether that is supervisory work or new policy initiatives, and this seems( or should I say seams) set to continue.

It has been pleasing to see that most firms of the firms with which we work have made a strong commitment to embedding Consumer Duty. In particular, we now see firms assessing themselves in a more objective light.

However, there are still some firms that are treating Consumer Duty as a rigid one-off annual exercise, rather than recognising its true objective, which is to continually monitor with a view to identifying areas for improvement. The Annual Board Report sign off is an opportunity to pause, take stock of the past twelve months, and plan for the next.

" The Annual Board Report sign off is an opportunity to pause, take stock of the past twelve months, and plan for the next."

From a procedural perspective, firms are now more process driven when it comes to giving advice. For example, we have seen many firms take time to review and challenge their investment and retirement propositions, to drive greater consistency of advice outcome. Where clients are receiving an ongoing service( and, for the vast majority of firms, this is a core service), firms have developed better quality monitoring frameworks, with proactive reminders for clients, enhanced clarity around service and costs, and clearer processes for disengagement.

From a client facing perspective, advisers take time to actively ensure that clients understand the advice they are being given includes risks and disadvantages, as well as recognising where additional time and space to consider recommendations may be needed, particularly in cases

Sandy McGregor, Director of Policy, Simplybiz

6 | The Adviser Online