Top 10 - Consumer Duty for asset managers

The FCA is introducing a new Consumer Duty, which is intended to provide higher standards of consumer protection across the financial services sector, by requiring firms to embed consumer outcomes in all aspects of their businesses. The Policy Statement setting out the final rules (PS22/9) was published in July.

Scope of this note

In this note, we consider the key scoping questions that are likely to be relevant to asset managers in determining if they will be in scope of the new rules.

We anticipate that some asset managers, particular alternatives sector firms and non-UK firms, will wish to confirm that they are not in scope of Consumer Duty. Where relevant, within the article itself, we have highlighted the potential basis to conclude that a firm is not in scope of the Consumer Duty in coral text boxes.

This note does not drill-down into the detail of Consumer Duty requirements for firms that must comply with the new regime. For further information on the new rules themselves, please refer to our separate notes on the Consumer Duty rules and guidance here.

Simmons & Simmons Consumer Duty Toolkit

Using our wealth of experience from working with many firms across the industry, we have custom-built a number of Board ready documents and training materials to support implementation, efficiently and cost effectively, no matter what stage of implementation you are at. We can support you with this in several ways:

Documentation

• Template Implementation Plan
• Template Board Pack
• Board Q&A’s
• Product/customer journey (a Pilot Sprint)

Training/briefings

• Board briefing
• Selection and briefing of Consumer Duty Champion
• Training for SMFs and CoCON staff

For more information on our toolkit visit our Consumer Duty webpage.