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Wealth Management

12 June 2023

The Consumer Duty sets higher expectations for asset and wealth managers to act to deliver good outcomes for consumers. Some of the requirements are an extension of current obligations whereas some are significant new requirements, including an increased focus on regulations relating to price and value, which is likely to contribute to ongoing pressure on fees.

To comply with the Consumer Duty, boards of wealth and asset management firms need to prioritise the implementation and embedding of robust processes. These processes should encompass testing consumer outcomes, ensuring the availability of effective management information, and fostering a corporate culture that encourages employees to prioritise the best interests of customers. This will be an ongoing process. 

In the wealth management world, the number and complexity of distribution arrangements throws up challenging questions for firms, for example to answer existing arrangements may amount to co-manufacturing and we fear platforms will have a significant burden as a 'gate keeper'. 

The Consumer Duty Hub, written by our team of experts, serves as a resource to assist senior managers in comprehending and implementing the necessary measures to fulfil the obligations mandated by the Duty.

Consumer Duty - Price and Value Outcome

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.

 
Consumer Duty: Consumer Understanding, Financial Promotions, and Communications 

This is the third article in the Consumer Duty wealth management sub-series. This article focuses on financial promotions and communications.

 
Consumer Duty Temperature Check & Assurance
Part of our Consumer Duty offering is a one-day ‘temperature check’ service, which is intended to provide you with a rapid and insightful review of your Consumer Duty compliance and alignment. We can also provide an independent assessment of firms’ culture and behaviours, to understand how it is supporting good customer outcomes.
 
Consumer Duty - Product Governance

This is the first of a series of articles looking at the Consumer Duty and its implications for the wealth management world. The distribution chain can be extremely complicated and consist of multiple product manufacturers (both for the actual investments and associated wrappers), platform provider, custodians, DFM, broker and/or financial adviser. Some will play a relatively minor role whereas others' will be significant. 

 
FCA speech on cultural evolution: How culture must change to meet expectations
Emily Shepperd, Chief Operating Officer and Executive Director of Authorisations at the FCA delivered a speech to the Westminster Business Forum highlighting the importance of culture for confidence and how it can dictate bottom lines.  
 

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