The FCA gave firms an additional year to apply the Duty to closed products and services. That second deadline passed last week on 31 July.

Across the industry, firms have worked hard to complete reviews of their closed products and will keep these under review going forwards. 31 July last week was also the deadline for firms to have assessed and reported on their implementation and delivery of the duty and its outcomes to their boards. Future reports, at least annually, may be scheduled around appropriate reporting cycles.

On fair value, UK Finance has supported mortgage lenders at an industry level with the development and publication of a standard product information sheet template and related information sharing guide for existing and new products and services. 

These resources can still be used in the context of closed products, although the product and services outcome does not apply in same way as for closed products – there being no target market or distribution strategy, for instance. 

The FCA has been clear that implementation of the Consumer Duty is not a “once and done” matter. Embedding change in firms that delivers the required customer outcomes will be an ongoing endeavour. 

As we move forward into Consumer Duty “business as usual”, firms will need to reflect on their learning from implementation, as well as looking at what their MI is telling them. They should use these metrics to assess where they are and what else they need to do next to improve and continue delivering.

Over the coming months, the FCA’s thematic and deep dive work will look at areas where firms have done well and areas where they could do better. The regulator is also expected to check that boards have the right data and MI, and review samples of board reports; sharing its findings with the industry to drive good practice.

Going forward, firms must consider and embrace emerging best practice on implementation of the duty. They must also ramp-up work to respond to the needs of vulnerable customers. This includes the regulator’s “tell us once” challenge - that customers should have to share their vulnerability needs and information with firms only once, rather than at multiple points and times in their customer journey.

Over the coming months, UK Finance will work across industry by developing a principles framework for information sharing on customer vulnerability between brokers and lenders. 

There is no doubt that industry has achieved a great deal for consumers in implementing the duty to date. But there is more to do. 

This includes responding to the FCA’s Call for Input on whether, where and how the regulator’s requirements can be simplified through greater reliance on high-level rules while continuing to support and protect consumers.

The consumer duty journey continues.