You will be familiar with the FCA’s Consumer Duty requirements with the first phase completion scheduled for July 2023. We wanted to share with you the progress we have made at Markham Private Clients and highlight the timetable of activity going forward.
Like many of you, we established a project team last year and conducted a gap analysis across our product lines over the Summer. Our plan received board approval in October 2022 and we have appointed a board member as Consumer Duty Champion. Our intention is that all our products are in scope.
Products & Pricing
- Our Product Review Process has been enhanced in line with ICOBS and PROD4 including fair value assessments and developing target market statements.
- We have implemented a new Fair Pricing Policy.
- You will have received communications from us requesting details of your remuneration ensuring collectively we can justify value in the distribution chain.
- If you need more information on the product review process, please email us.
- To support our customers who find themselves in vulnerable circumstances, we have drafted a Vulnerable Customer Policy.
- We have provided training to our people around identifying and supporting customers in a variety of vulnerable situations.
- We have produced cost of living and vulnerable customer research to help identify and support the precise challenges being faced by our customers.
- In order to meet communications requirements, we have drafted a series of Communication Principles for Policy Wordings and all customer communications.
- These principles focus on supporting consumer understanding by:
- ensuring that our communications meet the information needs of the reader;
- ensuring communications are clear, fair and not misleading;
- tailoring communications to take account of the characteristics of the customer (including vulnerability);
- ensuring that information is accurate, relevant and provided on a timely basis;
- checking and testing communications for customer understanding.
- Initially, high risk communications have been prioritised for review, ‘high risk’ has been identified as debt and arrears communications and claims communications where the communication has a call to action or important information which could cause customer detriment if not understood.
- We are also reviewing and analysing the use of current management information and ensuring that future MI requirements are catered for as part of this project – MI that will drive positive customer outcomes.
Going forward, we will be liaising with each of our partners to ensure we have all of the necessary tools and support in place to meet the Consumer Duty requirements.
We will share progress updates with you, we will be reviewing all existing agreements to ensure our respective roles and responsibilities are fully captured in line with the new requirements.
We will be sending further communications in the coming months with more specific information depending on the relationship we have with you.
We welcome any feedback from our distributors on the performance of our products. All feedback will be considered in our next product review.
If you believe that your staff would benefit from additional training on this product, please let us know by contacting [email protected]