On 9 October 2024, the Financial Conduct Authority (FCA) published its review into payment firms’ implementation of the Consumer Duty (Duty) and how they have considered the specific payments sector risks set out in the Dear CEO letter of 21 February 2023 on implementing the Duty in payments firms.
The types of payment firms the FCA reviewed included payment service providers, e-money issuers, money remitters, merchant acquirers and open banking firms.
For the review, the FCA contacted 23 payments firms and asked them how they had implemented the Duty. As part of this the regulator asked for documents evidencing the approach as well as raising specific questions. The FCA analysed the responses and sent feedback to the firms involved.
Findings
The FCA’s findings from the review include:
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Approach to implementation: The best firms tended to have strong governance and control frameworks which were used to scrutinise and challenge the firm’s implementation of the Duty and deliver an