The Financial Conduct Authority (FCA) said the duty could lead to a “significant shift” in expectations and noted that firms were working hard to meet the standards.
However, it said some firms still had more to do to meet the 31 July deadline.
The regulator said: “It’s crucial that firms are asking themselves the right questions, to make sure they are on track and making the most of the remaining time.”
The FCA said it expected the key questions to highlight where improvements were needed or any gaps. It also said firms would be asked similar questions when engaging with the regulator.
It added: “Once the duty is in force, we will prioritise the most serious breaches and act swiftly and assertively where we find evidence of harm or risk of harm to consumers.”
10 key questions for firms to consider
- Are you satisfied your products and services are well designed to meet the needs of consumers in the target market, and perform as expected? What testing has been conducted?
- Do your products or services have features that could risk harm for groups of customers with characteristics of vulnerability? If so, what changes to the design of your products and services are you making?
- What action have you taken as a result of your fair value assessments, and how are you ensuring this action is effective in improving consumer outcomes?
- What data, management information (MI) and other intelligence are you using to monitor the fair value of your products and services on an ongoing basis?
- How are you testing the effectiveness of your communications? How are you acting on these results?
- How do you adapt your communications to meet the needs of customers with characteristics of vulnerability, and how do you know these adaptions are effective?
- What assessment have you made about whether your customer support is meeting the needs of customers with characteristics of vulnerability? What data, MI and customer feedback is being used to support this assessment?
- How have you satisfied yourself that the quality and availability of any post-sale support you have is as good as your pre-sale support?
- Do individuals throughout your firm – including those in control and support functions – understand their role and responsibility in delivering the duty?
- Have you identified the key risks to your ability to deliver good outcomes to customers and put appropriate mitigants in place?
