Meeting the Consumer Duty deadlines ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌ ‌


Consumer Duty Update

Blackfinch takes our regulatory responsibilities very seriously and we believe the Financial Conduct Authority (FCA) Consumer Duty presents an opportunity for all of us to reflect on how well retail investor clients identify, understand, and choose appropriate investment solutions to achieve their personal goals and ambitions.

As a company, we have appointed a Consumer Duty Champion, Alex Sumner, who is also Blackfinch Group Commercial Director. Alex holds the certificate in Private Client Investment Advice and Management, Investment Advice Diploma, and CFA Certificate in ESG Investing. Working alongside Alex is a project team which consists of a cross-section of people from the organisation to ensure an unbiased and transparent approach.

Following the FCA’s final guidance in their Policy Statement (PS22/9) from July 2022 Blackfinch has undertaken reviews of our products and services taking into consideration the four consumer outcomes:

  • products and services,
  • price and value,
  • consumer understanding,
  • and consumer support.

In addition to internal reviews, we have also undertaken external research with those who have no experience of our investment solutions or marketing materials. This has provided an excellent opportunity for feedback and suggestions on how we could do better.

We are delighted to say that the results of our assessments are incredibly positive and constructive. On Tuesday, we will publish our full findings on our website.

To meet the end of July 2023 implementation deadline, the FCA requires all manufacturers to complete the assessment of their in-scope products and services and share all relevant information with their distributors by the end of April 2023 to allow distributors time to complete their own assessments.

Next week, we will begin to make some of the minor suggested changes to our literature that were made during our external research. We’ve enjoyed the process of seeing a fresh pair of eyes on our materials and we recognised that there are places where we can make improvements. Some examples include:

  • A simpler description of how our annual fee is calculated
  • Making sure we don’t use specialist terminology in market commentaries

These changes will all be made considerably ahead of the July Consumer Duty deadline.

We have also identified some useful tools that we can produce that will make it easier for Financial Advisers to meet their own obligations. When these become available we will add them to our Consumer Duty Library on our website. We welcome any ideas you have for more!

Blackfinch is committed to helping individuals, businesses and communities thrive. We fully embrace the Consumer Duty and look forward to sharing our findings with you next week.

1350-1360 Montpellier Court, Gloucester Business Park, Gloucester, GL3 4AH

Blackfinch Investments Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales No. 2705948. Registered Office: 1350-1360 Montpellier Court, Gloucester Business Park, Gloucester, GL3 4AH

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