--- title: Insights | Punter Southall Law | Consumer Duty description: Neville Hall, Punter Southall Law’s Partner, Risk and Compliance, offers his view on Consumer Duty image: https://www.puntersouthall.com/hubfs/consumer%20duty%20blog.jpg --- - [ Our services ](https://www.puntersouthall.com/our-services) - [ Pensions ](https://www.puntersouthall.com/pensions) - [ Defined benefit ](https://www.puntersouthall.com/defined-benefits) - [ Defined contribution ](https://www.puntersouthall.com/pensions#defined-contribution) - [ SIPP & SSAS ](https://www.puntersouthall.com/pensions#self-invested-pensions) - [ Expert witness ](https://www.puntersouthall.com/expert-witness) - [ Analytics ](https://www.puntersouthall.com/analytics) - [ Numbers for lawyers ](https://www.puntersouthall.com/analytics#numbers-for-lawyers) - [ Data compliance ](https://www.puntersouthall.com/analytics#data-compliance-for-data-confidence) - [ Legal ](https://puntersouthall.law/) - [ Employee benefits ](https://www.puntersouthall.com/service-update-apr-24) - [ Financial planning ](https://www.puntersouthall.com/service-update-apr-24) - [ Insights ](https://www.puntersouthall.com/insights) - [ Blogs ](https://www.puntersouthall.com/insights) - [ Our story ](https://www.puntersouthall.com/our-story) - [ People & culture ](https://www.puntersouthall.com/people-culture) - [ Our people ](https://www.puntersouthall.com/staff-directory) - [ Awards ](https://www.puntersouthall.com/awards) - [ Careers ](https://www.puntersouthall.com/careers) - [ Contact us ](https://www.puntersouthall.com/contact) [![Punter Southall - Animated icon](https://www.puntersouthall.com/hubfs/raw_assets/public/punter-southall-hc/library/images/client/logos/punter_southall_anim_logo.gif) ![Punter Southall - Text logo](https://www.puntersouthall.com/hubfs/raw_assets/public/punter-southall-hc/library/images/client/logos/punter_southall_text_logo.svg) ](https://www.puntersouthall.com/) ** ** ** - [ Our services ** ](https://www.puntersouthall.com/our-services) - [ Pensions ** ](https://www.puntersouthall.com/pensions) - [ Defined benefit ](https://www.puntersouthall.com/defined-benefits) - [ Defined contribution ](https://www.puntersouthall.com/pensions#defined-contribution) - [ SIPP & SSAS ](https://www.puntersouthall.com/pensions#self-invested-pensions) - [ Expert witness ](https://www.puntersouthall.com/expert-witness) - [ Analytics ** ](https://www.puntersouthall.com/analytics) - [ Numbers for lawyers ](https://www.puntersouthall.com/analytics#numbers-for-lawyers) - [ Data compliance ](https://www.puntersouthall.com/analytics#data-compliance-for-data-confidence) - [ Legal ** ](https://puntersouthall.law/) - [ Employee benefits ** ](https://www.puntersouthall.com/service-update-apr-24) - [ Financial planning ](https://www.puntersouthall.com/service-update-apr-24) - [ Insights ** ](https://www.puntersouthall.com/insights) - [ Blogs ** ](https://www.puntersouthall.com/insights) - [ Our story ](https://www.puntersouthall.com/our-story) - [ People & culture ** ](https://www.puntersouthall.com/people-culture) - [ Our people ** ](https://www.puntersouthall.com/staff-directory) - [ Awards ** ](https://www.puntersouthall.com/awards) - [ Careers ** ](https://www.puntersouthall.com/careers) - [ Contact us ](https://www.puntersouthall.com/contact) - ** ** Law 28 September 2023 [** Back ](https://www.puntersouthall.com/insights/) **Author:** Neville Hall # Fast Consumer Action: a regulator in a hurry Since Consumer Duty came into effect only 8 weeks ago, the FCA have already issued several ‘Dear CEO’ letters telling firms to step up. Fund managers have been told further work is needed on their value assessments and the proficiency of non-executive directors. Retail bank account closures and the treatment of PEPs continue to be scrutinised. Insurers have been instructed to do better on fair value of products across all sectors, but especially and immediately for GAP (guaranteed asset protection) car insurance. On the latter, the deadline for firms to actively demonstrate compliance to the FCA is short, just 12 weeks before the FCA will intervene. These are clear indicators that the FCA is in a hurry to prove Consumer Duty is real, and that enforcement starts now. There is no grace period. For FCA regulated firms with a retail touchpoint, the switch from building a Consumer Duty programme, to execution, output, monitoring, review, governance, and pro-active remediation if required, should be happening now. Those responsible for driving in-house Consumer Duty programmes need to be closely evaluating the detailed output, continuously. **Boards need to ensure that this is on the agenda now; and that the designated Consumer Duty Champion is fully briefed as to their responsibilities. Independent non-executive directors must get themselves trained if necessary, and actively participate and challenge what is put before them**. Boards also need to assess how their business strategy is consistent with delivering good outcomes under the Duty. **Board-level Consumer Duty reports need to be tangible and comprehensive, with multiple metrics to evidence conclusions**. By way of reminder, Chapter 11 of the FCA’s guidance is a good reference point for what should be included: - Business persistence, i.e. analysis of customer retention records - Distribution of products/pricing and fees and charges - Customer behavioural insights - Staff training and competence records, including remedial actions - Customer file reviews, including assessments of outcomes - Customer feedback - Numbers of complaints, including trend analyses - Complaints root cause analysis - Results of the regular testing and monitoring required under the outcome rules - Feedback from other parties in the distribution chain - Compliance reports - Researching or testing customer experiences through processes such as mystery shopping, auditing customer journeys, focus groups and deep dives, or working with consumer organisations to gain insight into the needs and experiences of consumers - Staff feedback - Reviewing whether processes and policies are effective in delivering good outcomes for customers - Drawing on external sources of data about consumer outcomes such as The Financial Lives survey At [Punter Southall Law](https://www.puntersouthall.com/law), we have a team of highly skilled risk, compliance and legal experts with deep in-house practical experience. If you would like a friendly chat with one of us, [get in touch](mailto:Neville%20Hall%20%3cNeville.Hall@puntersouthall.law%3e) Share [** ](mailto:?subject=Fast%20Consumer%20Action:%20a%20regulator%20in%20a%20hurry&body=https://www.puntersouthall.com/insights/fast-consumer-action-a-regulator-in-a-hurry) [** ](http://twitter.com/intent/tweet?text=Fast%20Consumer%20Action:%20a%20regulator%20in%20a%20hurry&url=https://www.puntersouthall.com/insights/fast-consumer-action-a-regulator-in-a-hurry) [** ](http://www.linkedin.com/shareArticle?mini=true&url=https://www.puntersouthall.com/insights/fast-consumer-action-a-regulator-in-a-hurry) [** ](https://www.facebook.com/sharer/sharer.php?u=https://www.puntersouthall.com/insights/fast-consumer-action-a-regulator-in-a-hurry) [** Back ](https://www.puntersouthall.com/insights/) ### Get in touch today At Punter Southall, we have a team of highly skilled risk, compliance and legal experts with deep in-house practical experience. Get in tough if you would like a friendly chat with one of us. Get in touch** - LATEST UPDATES ## You may also be interested in [Law ](https://www.puntersouthall.com/insights/punter-southall-law-partner-martin-finnegan-shares-his-thoughts-as-a-guest-speaker-at-the-recent-app-workshop) - 17 November 2022 [Punter Southall Law Partner, Martin Finnegan, shares his thoughts as a guest speaker at the recent APP Workshop](https://www.puntersouthall.com/insights/punter-southall-law-partner-martin-finnegan-shares-his-thoughts-as-a-guest-speaker-at-the-recent-app-workshop) [Read article](https://www.puntersouthall.com/insights/punter-southall-law-partner-martin-finnegan-shares-his-thoughts-as-a-guest-speaker-at-the-recent-app-workshop) [Law ](https://www.puntersouthall.com/insights/an-introduction-to-nick-holt) - 21 January 2022 [An introduction to Nick Holt - our Director of Development](https://www.puntersouthall.com/insights/an-introduction-to-nick-holt) [Read article](https://www.puntersouthall.com/insights/an-introduction-to-nick-holt) [Law ](https://www.puntersouthall.com/insights/fca-challenges-nine-firms-on-savings-products-consumer-duty-in-action) - 4 September 2023 [FCA challenges nine firms on savings products: Consumer Duty in action](https://www.puntersouthall.com/insights/fca-challenges-nine-firms-on-savings-products-consumer-duty-in-action) [Read article](https://www.puntersouthall.com/insights/fca-challenges-nine-firms-on-savings-products-consumer-duty-in-action) - ###### INSIGHTS #### Subscribe to updates Where we share what we’re thinking about and what conclusions can be drawn on everything from the work we do to the world around us. 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