The FCA recently published the findings from its Spring 2023 survey of readiness for the Consumer Duty implementation deadline which is now looming fast - just two weeks from next Monday! 

The survey was not industry wide but targeted on certain select areas which it was thought might be less ready including smaller firms and firms for which financial services is not the main line of business. The survey results suggested "very high levels of engagement and understanding" of the Consumer Duty with over half of the firms surveyed suggesting that they would be "fully compliant by the deadline".

Unsurprisingly, there was a percentage of firms included in the survey confessing to still having work to do or even to start and that included "retail finance providers and debt advice firms" which the FCA includes in its assessment of firms scoring "consistently lower than others on engagement, understanding, and implementation progress". 

The FCA has produced a number of online resources, including more detailed resources designed in response to requests from firms for more specific information, to assist firms in making the transition to a regulatory world that is focused on consumer outcomes.  

In the remaining few weeks there will be much to do even for firms that have planned well ahead and fully engaged with the requirements and the work needed in order to implement them into their policies and procedures. For those firms that are some way off being able to meet the deadline, or have not yet taken the new consumer outcomes approach seriously, it is expected that the FCA will take robust action particularly in cases where there is actual or potential harm to consumers.

The FCA has stated that it will use the intelligence gathered during the survey to target further supervisory activity and firms active within the areas identified as being inadequately prepared can expect to find themselves subject to further FCA scrutiny. The FCA suggests that any firm at risk of being in breach of the Consumer Duty at the end of this month should consider giving priority to the "work that is likely to have the greatest impact on consumer outcomes" with firms who assess their risk of non-compliance with the Consumer Duty as "significant" being advised to alert the FCA and enter a dialogue.