Written on 25/07/2023

The four week response letter has been staple fayre for IFAs and mortgage brokers for many years.  You must resolve the complaint within 4 weeks, or write to the client to explain away the delay, and provide another four week response timeframe.  This was hitherto bedded into DISP 1.4.4.

Now IFAC have noticed that this rule has magically disappeared, without any publicity from the FCA, and been replaced by the 8 week only rule listed HERE as DISP 1.6.

As if by magic, our job is a little easier.  The FCA like complaints to be resolved within this 8 week window, but where not possible, another holding letter must go out, outlining how much more time the firm might expect this to take.  Almost all compliance manuals in use by firms in retail financial services mention the 4 week letter.  You could argue that firms should remove this paragraph, to bring the manuals into line with the FCA handbook.  IFAC believe that 4 weeks is quite long enough for a complainant to be kept waiting with no updates, and that it is wise to retain this 4 week discipline.  In fact, in an age of emails, the response should only take a minute, to reassure the complainant that the firm is still looking into the case, and will revert shortly, but in any case within another four weeks.

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