Tailored sector specific support
Banks and Bank Challengers
We assist Banks and Bank Challengers to embed the 'Duty' requirements. The Consumer Duty came into force in 2023 for open products and in July 2024 the regime was extended to include closed product (products that are no longer on sale).
The FCA have been clear that 'Consumer Duty is not once and done'. It's an ongoing set of standards that firms must keep in mind at every stage of a products lifecycle and embrace as part of their culture'.
Delmere assists clients to ensure that they can demonstrate ongoing efforts to:
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deliver against the four 'Consumer Duty' outcomes,
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ensure that good governance is in place
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maintain appropriate oversight
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onitor performance through accurate, timely and relevant data
We also provide 'Duty Champion' and Consumer Duty Board advisory services.
Electronic Money Issuers (eMoney)
It's essential that eMoney firms work with all their commercial and delivery partners across the entire distribution chain. This is a specific area of focus for Delmere and our clients, supporting effective implementation of Consumer Duty responsibilities. It is particularly important where agents and distributors help to provide services to end users. The regulated firm is ultimately responsible under the 'Duty' for all Customer outcomes and we help to ensure that appropriate procedures are put in place to satisfy yourselves that the 'Duty' is being met on an ongoing basis.
Areas of focus often include:
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helping to demonstrate that Customers receive fair value, and Customers are provided with relevant product information in a manner that they can understand,
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the use of data and management information to monitor whether services continue to meet customer needs and deliver good Customer outcomes,
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assessing whether services have features that could cause harm to vulnerable customers, and ensuring actions are available to mitigate the risk of harm,
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obtaining and sharing all necessary information with other firms in the distribution chain to enable them to comply with the 'Duty',
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helping you to demonstrate that Customers are provided with support that meets their needs through the full lifecycle of the product or service, this includes support where fraudulent activity is suspected,
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providing Consumer Duty Champion and Board advisory services (including Board reports and annual attestation).
Open Banking Providers
In addition to the areas highlighted above, it's imperative that Open Banking firms who provide services to Customers, ensure that their Customers understand what they are consenting to in terms of allowing Open Banking firms to access their accounts.
Delmere helps clients to ensure that propositions are meeting the 'consumer understanding' outcome on an ongoing basis.
Other Sectors
At Delmere, we work with regulated firms across all sectors that are required to implement and embed Consumer Duty requirements. We also work with organisations that are not directly regulated themselves, but support regulated firms as an agent, distributor or critical supplier.
Please get in touch and we will be happy to discuss how we can help you.