The FCA on 9 October 2024 published its key findings from its review of payment firms' implementation of the Consumer Duty, which came into force for open products and services on 31 July 2023 and for closed products on 31 July 2024.
The FCA rated around half of the firms as satisfactory and did not consider them to present a risk of significant poor consumer outcomes. The remaining half of the firms had not implemented the Duty in a satisfactory manner. The FCA noted that the most compliant firms tended to be systematic in implementation, actively scrutinising their current processes in light of the Duty whereas non-compliant firms tended to rely on their pre-existing processes and controls.
The authors
Lewis Baxter
and then 