Since the FCA introduced plans for Consumer Duty, firms and individuals alike have been working hard to ensure they deliver against the new requirements. However, whilst there has been a lot of work put into implementing the cross-cutting rules, and the four consumer outcomes, very little has been said about the “employee” dimension, other than in respect of the Conduct Rules.
If asked, would your organisation be confident to hand over their Training & Competence records to the regulator? If they asked to see your T&C Regime pre-Consumer Duty and post, would it really look any different? If asked, could your firm demonstrate analysis and decisions around appropriate MI to evidence that your T&C scheme supports good consumer outcomes? Would being asked to demonstrate “role relevant” training on conduct rules to staff make you start to feel a little uncomfortable?
Regardless of whether you might answer Yes/No/Don’t know to any one of those questions, we think your input and perspective would add value to our debate on the topic, so the Worksmart team to discuss:
1. The regulators expectations of your T&C Regime
2. What analysis and changes have you made to your T&C arrangements in light of Consumer Duty
3. What does a good T&C regime look like under Consumer Duty?
4. How you can evidence, measure, and monitor the competence of the staff to deliver defined customer outcomes
5. How can your T&C arrangements support Culture change in your firm
6. How RegTech can improve your approach to T&C