Written on 16/12/2022


Message to all IFAs and Mortgage brokers:  have you completed your consumer duty plan?

Your biggest risk remains the counterparties: the lenders and providers are under pressure from FCA to report their findings to FCA about brokers.  They are now relentlessly reviewing their mortgage and life insurance agencies with brokers with an eye on Consumer Duty – increasingly seeking to impose special terms on some, and terminating others.  This is the Consumer Duty in action.

IFAC help with appeal processes, and help setting up new agencies, but the best result is to avoid raising eyebrows in the first place at these counterparties.   The quality of your Consumer Duty Plan will be an important part of your armoury.  It is not easy, and takes imagination for a small business to articulate for a regulator what many leaders do over their breakfast cereal – segmenting clients, adjusting prices and services and helping with complaints, that often appear unreasonable.

A number of firms have sent to us their plans to check and approve.  Our response, apart from a cursory comment on look and feel, is that we validate your plans and worthy statements of intent as part of your annual audit.

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