Compliance Monitor
Portfolio letters - specifics of the Consumer Duty
"Portfolio and Dear CEO letters both have an appealing feature. The regulator is coming off the usual fence." Adam Samuel dissects granular commentary from the Financial Conduct Authority's correspondence tool du jour.
Adam SamuelBA LLM DipPFS MCISI FCIArb Certs CII (MP&ER) Barrister and Attorney may be contacted atadamsamuel@aol.com.You can purchase Adam's latest book 'Compliance - a Short Book' at www.amazon.co.uk/Compliance-Short-Book-Adam-Samuel-ebook/dp/B0CTRYBN1J/. For links to where you can buy the second edition of 'Consumer Financial Services Complaints and Compensation', seewww.adamsamuel.com/writing.
Followers of the Consumer Duty will know that the regulator uses a combination of general updates and what it calls 'portfolio letters' to communicate its views on how firms of different types should comply with the rules. These documents play a number of intriguing roles in FCA-regulation. Typically, they do not propose regulatory changes or even foreshadow them. They attempt to give the regulator's understanding of the issues firms face in either complying with rules that exist or will shortly come into force. Many attempt to explain how the Consumer Duty applies to different firms but not all do or even relate to firms who deal with consumers.