International
Asia Pacific
EMEA
North America
Latin America
On 27 July 2022, the FCA published its highly anticipated final rules and guidance on the new Consumer Duty, ushering in a fundamental cultural shift in the way that regulated firms will approach and serve customers, and starting the countdown clock for implementation plans across the industry.
In a welcome move, the FCA has now confirmed a phased approach to implementation. Firms will need to apply the Consumer Duty to new and existing products and services that are open to sale (or renewal) from 31 July 2023. Firms will have an additional 12 months, until 31 July 2024, to apply the Consumer Duty to products and services held in closed books. Despite this phased approach, boards are expected to have scrutinised and signed off firms’ implementation plans by the end of October 2022 so time is tight for firms to agree their approach to implementation.
On the whole, the final Consumer Duty package reflects the proposals set out in the FCA's consultations, with some changes and clarifications made in response to feedback received. Going forward, The FCA expects to build on the guidance as the Consumer Duty is embedded across the industry, including more sector specific guidance over time. In this alert, we highlight some of the significant changes and clarifications that we consider to be most significant. For more detail on the proposals as consulted on, this alert should be read together with our previous alerts of June and December 2021.
Please read the full alert here.
Copyright © 2024 Baker & McKenzie. All rights reserved. Ownership: This documentation and content (Content) is a proprietary resource owned exclusively by Baker McKenzie (meaning Baker & McKenzie International and its member firms). The Content is protected under international copyright conventions. Use of this Content does not of itself create a contractual relationship, nor any attorney/client relationship, between Baker McKenzie and any person. Non-reliance and exclusion: All Content is for informational purposes only and may not reflect the most current legal and regulatory developments. All summaries of the laws, regulations and practice are subject to change. The Content is not offered as legal or professional advice for any specific matter. It is not intended to be a substitute for reference to (and compliance with) the detailed provisions of applicable laws, rules, regulations or forms. Legal advice should always be sought before taking any action or refraining from taking any action based on any Content. Baker McKenzie and the editors and the contributing authors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The Content may contain links to external websites and external websites may link to the Content. Baker McKenzie is not responsible for the content or operation of any such external sites and disclaims all liability, howsoever occurring, in respect of the content or operation of any such external websites. Attorney Advertising: This Content may qualify as “Attorney Advertising” requiring notice in some jurisdictions. To the extent that this Content may qualify as Attorney Advertising, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. Reproduction: Reproduction of reasonable portions of the Content is permitted provided that (i) such reproductions are made available free of charge and for non-commercial purposes, (ii) such reproductions are properly attributed to Baker McKenzie, (iii) the portion of the Content being reproduced is not altered or made available in a manner that modifies the Content or presents the Content being reproduced in a false light and (iv) notice is made to the disclaimers included on the Content. The permission to re-copy does not allow for incorporation of any substantial portion of the Content in any work or publication, whether in hard copy, electronic or any other form or for commercial purposes.
Are you sure want to delete comment ?
Scan this QR Code to share this content
