It also included clear examination of the total price paid relative to the benefits that customers are expected to receive over their lifetime and taking a holistic approach by not just focusing on price of value but also in terms of customer understanding and support.
Cashman pointed out firms that work with consultants, who have given them high quality applications to work with, are unable to translate exactly how that works into practice for their own business.
He said: “I would encourage those firms to perhaps spend a bit more time with the consultant and work through exactly how it works and how they will explain it to us, and then be able to explain to their customers how that will work in practice.
“And I would absolutely draw people's attention to the guidance that we've published on the website. We've spent a lot of time over the last couple of years giving a lot more extensive guidance. So definitely worth people spending some time looking through all of that through that application process.”
Call To Input
Reynolds discussed the FCA’s Call To Input that was published this week, looking at whether the regulator may be able to change some of its rules given the implementation of the consumer duty.
He said: “We know that many firms feel a little bit differently about the level of prescription that one might have. Some firms really like a little bit of prescription in what they need to do. Some firms really want that flexibility.
“And one of the things we want to explore through that discussion is when is that prescriptiveness really helpful and important, and when actually, do you want that greater flexibility?
“We think that really comes through when we look at firms of different sizes as well. We know that some small firms want to have some of that flexibility. Some small firms want that prescriptiveness, so we'd like to make sure that is a central part of the discussion that we have over the coming months as well.”
alina.khan@ft.com
