I admit to putting off reading the first five chapters of the consumer duty as instructed by my compliance officer. I have now done so and a few selected chapters more, diligently noting salient paragraphs and rehearsing over-riding principles, cross-cutting rules and key outcomes.
But I now treat Finalised Guidance 22-5 with the reverence normally reserved for the bible. And I admit that I put reading it above a three hour Good Friday vigil at the Wesleyan Chapel. My reward will be a compliant business but I doubt I’ve ascended another rung of Jacob’s ladder.
It is a document that teaches us how to be good – 121 pages of “non-handbook” guidance asking us to know our customers, meet our customers needs and above all demonstrate that we are compliant.
To which end, many an FCA regulated firm’s Easter Weekend will be dedicated to establishing consumer duty dashboards that evidence that the customer is at the heart of everything everyone does.
You can check how you’ve done with Keith Richards on Tuesday
So how was my day with FG 22-5?
It was very dull.
The trouble is that there is nothing in the Consumer Duty that is anything but common sense. It is not a revolutionary document, it simply restates best practice in a highly methodical fashion to a point where it will undoubtedly improve standards and get consumers better value for money from financial products – including advice.
Pretending that putting in place the processes, the data collection systems and the dashboards to display we have control over our businesses , is hugely important,
There are brilliant people who can get us there – I like the approach taken by MoneyHub.
But you can buy all the systems and document all the processes you like, if this consumer duty isn’t second nature, you will find it hard to be compliant.
Which is why today, I will spend another day reading, and thinking and asking the questions of myself and my team that need to be asked.
And when I have done, and at the end of this lovely , sunny weekend, I emerge with everything in my head straight and the clearest of plans. I will sing this song.