The FCA has published the results of its multi-firm review into how 23 payments firms have implemented the Consumer Duty. It carried out its survey in January, and included firms from across the payments portfolio. It rated just over half the firms as satisfactory but found the other half had only partially implemented the Duty and significant work was needed to comply with it. Key messages were:
Good practice
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the best firms had a systematic approach to implementation, working from identifying their target markets and what the good outcomes would look like in each area, and had a clear governance strategy to monitor compliance and address shortcomings
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regular summary MI aligned to each outcome using RAG ratings to report to the Board worked well
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firms applying high monitoring standards with MI reports on agents as well as themselves
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having metrics that were clearly aligned to and evidenced Duty outcomes
Concerns
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some firms thought their products did not present risks to con