“It's also trying to do something to really reinforce at every level of the value chain, really trying to put it to the back, front and centre in business models in some cases.”
The consumer duty deadline was just over a month ago (July 31) and the panelists looked at how firms have performed.
From Woolard’s perspective, firms did understand that this was the FCA’s biggest change in regulation for about a decade.
“That message got through quite quickly, we saw people really take it seriously,” he said.
“Equally, I think once people began to think about the scale of change and what it meant, then there was the triage exercise.
“There has been lots of activity but still, an enormous amount to just make sure this is embedded,” he said.
In terms of fair value, Bhandal explained that there is a process point that might seem academic, but there is the assessment of value process.
“That is backward looking - it's used as a backward looking metric,” she said.
“So are charges justified, whereas consumer duty is a forward looking assessment, so is the price reasonable relative to the benefits and for recent foreseeable period, and that in itself has created complexity because you do have issues here where some parts of the market will be doing AOV, but there'll be some parts of the market who are obviously having a non AOV so fair value is quite subjective.”
sonia.rach@ft.com
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