Consumer Duty – the Role of HR

Outline & Objectives

Following two consultations, the FCA appears committed to going ahead with its proposals to establish a new Consumer Duty. This will apply directly to all firms involved in retail activity and will also have implications for firms involved in wholesale and institutional business. The Consumer Duty will create an additional FCA Principle, three cross-cutting rules for all regulated sectors and four specific outcomes for the firm-customer relationship. 

As proposed, the Consumer Duty will result in major changes to the conduct requirements and reporting arrangements in all retail and retail-connected businesses.  To implement it, significant changes are proposed in regard to senior management’s obligations under the Senior Managers and Certification Regime and also to the Conduct Rules, where a new Conduct Rule will apply to all staff. In addition, to support the Consumer Duty, a number of changes will need to be made to firms’ HR policies and procedures, including Training and Competence arrangements, incentive schemes and performance management and appraisal regimes.

FCA is expecting firms to start preparing now for the implementation of these changes which will come into force in Spring 2023.

Attending this focused half day course will help you:

1. Review the areas of HR activity impacted by FCA regulation
2. Identify the principal features of the Consumer Duty
3. Examine how the Consumer Duty will interact with the SMCR and its implications for operating the Senior Managers Regime
4. Consider the impact of the Consumer Duty on the reassessment of fitness and propriety
5. Highlight the implications of the new Conduct Rule 6
6. Explore the effect of the Consumer Duty on culture initiatives
7. Identify ways in which the Consumer Duty obligations can be embedded within a firm’s HR policies and procedures

Who will benefit?

Anyone responsible for key HR activities within a financial services organization, especially those involved directly or indirectly with retail business.  This encompasses: Talent Management, Employee Benefits, Recruitment, Training, L&D, Organisational Development, Administration and Record Keeping. The course is also valuable for individuals in Risk, Compliance and Audit with responsibilities for monitoring HR activities.

Course Programme

Topics covered may include but are not limited to:

• HR in a regulated environment
• What is the Consumer Duty?
• The Consumer Duty and the SMCR
• The Consumer Duty and the Conduct Rules
• The Consumer Duty and Culture
• Embedding the Consumer Duty