Global Trustee and Fiduciary Services Bite-Sized Issue 3 2024

Global Trustee and Fiduciary Services Bite-Sized | Issue 3 | 2024 17 QUICK LINKS AIFMD CYBERSECURITY DIGITALISATION DORA EMIR LIBOR FSB IOSCO MICA MIFID II/MIFIR MONEY MARKET FUNDS OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG ASIA EUROPE IRELAND LUXEMBOURG NORTH AMERICA SWITZERLAND UNITED KINGDOM Consumer Duty Firm Survey – Autumn 2023 On 20 February 2024, the FCA announced that further to its Spring 2023 Survey to understand how firms were preparing for the 31 July 2023 implementation date, in Autumn 2023 it engaged Ipsos UK to conduct a second survey with 634 firms not surveyed previously. The FCA explain that the smaller firm sample means it is only drawing conclusions about firms surveyed, not all firms in scope of the Consumer Duty. The FCA highlights the following key information: • The proportion of firms surveyed reporting that they have completed the required steps has significantly increased for some portfolios, and 43% of firms surveyed reported that they are not having difficulty with implementing any aspects of the Consumer Duty. • Retail Finance Providers and Debt Advice Firms, sectors which lagged behind others in preparedness in Spring, report improvement bringing them closer to other sectors. This showed the benefits of our targeted engagement. • The percentage of firms surveyed that are conducting relevant activities have increased for several key elements of the Consumer Duty. Firms are most likely to report that they have identified the target market for their products and services (74%), and nominated a member of staff, team, or committee to oversee implementation (73%).​ • At wave 2, 74% of firms surveyed also report that they have conducted a fair value assessment. • Outcomes monitoring is reported as most difficult to implement, with Payment Services Firms (41%) and Wealth Management firms (36%) most likely to report this. • 38% of firms surveyed have improved significant consumer contracts and 30% of firms have identified or made significant improvements to their marketing strategies. The FCA says it was particularly interested in how smaller firms (1-49 employees) had implemented the Consumer Duty and whether firms had made changes to their consumer contracts and financial promotions. Link to Autumn 2023 Survey here