When is an adviser a manufacturer?
Consumer Duty frequently makes reference to ‘advisers’ and ‘manufacturers’– implying for many that there is a difference in responsibility between these. After all – advisers advise, and manufacturers create products. However, in this episode of Duty Calls, Tony Crane and Andrew Gething explore how – under the Consumer Duty – advice firms are classified as manufacturers (because the FCA’s definition includes a firm’s advice service making it a manufacturer of the services the firm provides).
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.