Consumer Duty

The FCA’s Consumer Duty sets higher and clearer standards of consumer protection across financial services and requires firms to deliver good outcomes for customers and clients.

This page gives an overview of the Consumer Duty and details what Royal London Asset Management is doing to meet the requirements.

The standards include the suitability of products that have been recommended to a customer, the quality and clarity of verbal and written communications, the quality of the pre-sale and post-sale service offered, and whether the support given helps customers to make financial decisions about their future. All of these areas include customers with vulnerabilities. 

This greater focus on consumer outcomes means that financial services firms are required to actively assess, improve and evidence how their actions and processes are working to deliver good outcomes for customers. 

The Consumer Duty is made up of:

1. The consumer principle
2. Three cross-cutting rules and
3. Four customer outcomes

What is the consumer principle? 

The consumer principle reflects the overall standard of behaviour and requires firms “to act to deliver good outcomes for retail customers”.

What are the cross-cutting rules? 

These are a set of rules that convey the standards of conduct that the FCA expects and articulate how firms should act to achieve good outcomes for their clients: 

• Act in good faith toward retail customers 
• Avoid foreseeable harm to retail customers  
• Enable and support retail customers to pursue their financial objectives. 

What are the four outcomes? 

The Consumer Duty expects advisers and providers to meet the requirements of four specific outcomes. They cover four distinct aspects of the relationship between firms and their clients:  

1. Products and Services 
2. Price and Value 
3. Consumer Understanding
4. Consumer Support

What are the Consumer Duty deadlines? 

The Financial Conduct Authority (FCA) has set the following deadlines for the Consumer Duty:

• By October 2022: The FCA asked all firms and providers to agree and document their Consumer Duty implementation plans
• By April 2023: Providers needed to have communicated their fair value assessments for their open products which are products available to retail customers. For our products this means the current Assessment of Value (AoV)
• By July 2023: Financial service providers needed to be able to evidence their firm is meeting the new standards

What has Royal London Asset Management done to meet the Duty?

We have taken steps to ensure we are delivering our obligations under the four outcomes:

Products and Services

• We have assessed all of our funds to ensure they are targeting the correct customers and will continue to do so on an ongoing basis

Price and Value

• We already publish AoV reports for the RLUTM and RLUM fund ranges on our website
• We will publish the new European MiFID template v4.1 to provide additional fund details to distributors

Consumer Understanding

• We have worked with an external agency to assess both the requirements of the retail market and the suitability of our materials to retail customers

Consumer Support

• We have used customer inputs to enhance customer service and improve customer statements and other mailing

Further information and guidance

The FCA has published additional information here:

The FCA's guidance on Consumer Duty 

 A new Consumer Duty: Feedback to CP21/36 and final rules 

FG22/5 Final non-Handbook Guidance for firms on the Consumer Duty 

Consumer Duty webinar – consumer investment, pensions, asset management firms 

FCA Consumer Duty podcasts