Regulated members can view an easy to digest timeline giving the implementation dates and requirements to be met by those dates for the Financial Conduct Authority (FCA)'s new Consumer Duty and Appointed Representatives (AR) regimes.
Consumer Duty
Past:
- 31 October 2022 - the due date for implementation plans has now passed. Implementation plans should be reviewed, approved and signed off by board level or equivalent.
- See the BVRLA's Implementation Plan guidance and checklist.
Future:
- 30 April 2023 - Manufacturers to have completed their reviews to meet the outcome rules. Guidance on this can be found in the BVRLA's Consumer Duty deep dive webinar series.
- 31 July 2023 - Distributors to have completed their reviews to meet the outcome rules. Rules come into play for open products and services. Guidance on this can be found in the BVRLA's Consumer Duty deep dive webinar series, Exploring Consumer Duty with the FCA webinar and Consumer Duty FAQ page.
- 31 July 2024 - Rules come into play for closed products and services. Guidance on this can be found in the BVRLA's Consumer Duty deep dive webinar series and in the Consumer Duty factsheet.
Also see the BVRLA's Consumer Duty guidance page.
Information on the BVRLA's training course Implementing the new Consumer Duty in your Brokerage.
Changes to the AR regime
The FCA have made changes to the Principal/Appointed Representatives (AR) Regime to improve and strengthen their oversight and supervisory.
These changes come into play from the 8 December 2022 which is also when the FCA will issue a section 165 information request to firms operating using this model. Firms should respond to this request by the 28 February 2023.