Mills commented: "The equivalent of a Google Shopping search does not prove to us that a customer is getting a fair deal."
We want to see firms considering all the aspects of fair value at the product level and considering the impact on different consumers.
Board reports will come under greater scrutiny as we look to these to evidence the steps firms are taking to drive good outcomes.
Main challenges
From the end of July, the requirements of the duty will apply to closed products as they do to open products.
The FCA said the main challenges firms have identified around closed products include:
- Being able to evidence you’re delivering good outcomes for consumers, and addressing gaps in the customer data you hold.
- Determining fair value on closed products.
- Taking action relating to less engaged and the ‘gone away’ customers, including the support offered and how you assess whether these customers understand the products they hold.
- Ensuring that the design of your products and services deliver good consumer outcomes over the long haul, even where your firm has vested rights.
Another challenge he identified was vested rights, which could include annual fees that are due or exit charges on products such as life insurance policies.
simoney.kyriakou@ft.com
