Following previous updates, I attended a regular meeting with the FCA in July and discussed queries raised by our Council members. We can share that the FCA will continue to request regulated firms for their Annual Consumer Duty Reports. It is a good idea to check that you have added the meeting minutes to your board document following the review of your annual report which, must have been completed prior to 31 July 24. The NPA understand that reports will evolve and reports will be proportionate to the size of your business. Please inform the NPA should the FCA contact you to see your Consumer Duty report as this will keep us up to date with how many members in total have been included.
The consistent messages are; looking after individual customers, documenting your actions and are your outcomes good for consumers. We would suggest that you review your business practices as if your grandmother was your customer and consider how you could avoid foreseeable harm?
We have asked the FCA if they could produce a Consumer Duty Reporting Flow chart, clarifying to members what data has to be submitted. The FCA are unable to produce this report, as it would result in completing a similar exercise for all markets.
The NPA is working with the Compliance Team at Cash Converters on producing a redacted flow chart solely for pawnbrokers who will need to complete the new Product Sales Data Report. The FCA have agreed to review the completed document and provide meaningful feedback. Once received Cash Converters have kindly agreed to share with all members who are required to complete the new Product Sales Data Report.
Consumer Duty 1 Year on
Peter Kenyon (NPA President) and I, along with many other trade associations attended a meeting in Stratford at the FCAs’ HQ. The FCA and FOS delivered their presentations followed by a panel session to answer questions. Finally, we were split into sector specific groups to complete a Q&A session with the FCA and FOS. The tone of the messaging was very much working with trade associations in a more collaborative way than may have been the case previously.