What’s the difference between guidance and rules?
Tony Crane and Andrew Gething look at Consumer Duty’s ‘guidance’ and ‘rules’ to unpick whether – in real-world terms – there is a difference between these and the implications of deciding to ignore guidance even when following rules. Tony leads Andrew back to the principle that firms should be delivering good outcomes and that everything supports this – and in that sense there is little difference between the two. More importantly, deciding to comply with one and not the other misses the overarching principle of delivering good outcomes and avoiding harms.
Latest white paper
Understanding the implications of vulnerability within Consumer Duty
Our latest Consumer Duty white paper
This paper examines the FCA Handbook Rules on Consumer Duty Regulations, specifically Principle 12. We extracted some key rules in order to explain the practical implications.
Latest podcast
What is a vulnerability?
Our latest Consumer Duty podcast
There is still a great deal of uncertainty about how someone is defined as vulnerable; what a vulnerability is. The FCA’s data (confirmed with live data from MorganAsh’s vulnerable consumer management tool, MARS) shows that around half of all people can be defined as vulnerable. Yet others say that they have only a few per cent of vulnerable consumers. Can this be true? Andrew Gething and Johnny Timpson OBE try to dig into the answers.
Latest webinar
Managing vulnerability in consumer credit
Our latest Consumer Duty webinar
The FCA has announced that it is reviewing how vulnerability is being managed. What are the practical implications for consumer credit, particularly in the motor finance sector, where credit is so important? We look at: what does consumer vulnerability look like, and what is required under Consumer Duty in consumer credit? We talk about the elephant in the room – the sale – the conflict of assessing consumers and minimising friction in the sale. And we ask what are the costs, benefits and risks of assessing consumer vulnerability? We also look at: personalisation of communications, comparisons of buying journeys, what the motor finance sector ‘doesn’t know’ about other areas of financial services – and we talk about the FCA’s current thinking and offer insights into what’s coming down the line from the regulator.