Consumer Duty - Price and Value outcome

19 July 2022

The next article in our series focuses on the 'Price and Value outcome' of the Consumer Duty, including the question of 'fair value'. With its increasing focus on price and value, we have been wary that the FCA is moving closer and closer to price regulation. Whilst this doesn't appear expressly on the FCA's agenda, and perhaps is unlikely to happen in the true sense, the FCA's focus on fair value is, in our view, a step in that direction.

The specific focus of the Price and Value outcome is on the relationship between the price the consumer pays and the overall benefits of a product (e.g. the nature, quality and benefits the customer will experience from the product or service). We consider the current guidance as well as comparing examples from across other sub-sectors in order to help assist firms determine their relevant considerations. We also identify some potentially interesting/tricky scenarios firms will want to consider.

This is the second article of our wealth management focussed Consumer Duty series. For all other articles, please see below.