FCA GI Consumer Duty and Multi-Occupancy Update

We are now live with Consumer Duty the FCA has urged firms to get on with it! Sheldon Mills, Executive Director of Consumers and Competition, warned that firms who ignore the Duty or who pose the most harm can expect swift action.

“Our supervisory and enforcement approach will be proportionate to the harm - or risk of harm - to consumers, with a sharp focus on outcomes. We will prioritise the most serious breaches and act swiftly and assertively where we find evidence of harm or risk of harm to consumers. In some cases, firms can expect us to take robust action, such as interventions or investigations, along with possible disciplinary sanctions.”

52 million financial services consumers in the UK rely on the sector to deliver good outcomes, and should be even better protected from harm, particularly in these challenging economic times. The Duty will mean that consumers should receive communications they can understand, products and services that meet their needs/provide evidenced fair value, and they get the customer support they need, when they need it.

The current cost of living squeeze makes it all the more vital consumers get fair value, and this should also benefit the competitiveness of the industry as firms strive to offer the best to compete for customers.

Market-wide portfolio letters were sent on 20 September 2023 highlighting key areas required for improvement across personal/commercial/wholesale lines and this update will be part of the talk.

We will also cover the new rules that will be effective from 1 January 2024 on multi-occupancy insurances following intervention by the government – these new rules will impact 5 million leaseholders. Leaseholders will be defined as customers and firms will have to act in their best interests and no commission sharing will be allowed with PMAs unless clear value to the leaseholder is evidenced. Insurers and brokers will also need to provide more information about policies to leaseholders, including detail of all remuneration.

Learning objectives - by the end of this update you will gain an overview of:-

• Where are we with Consumer Duty and what you should have done;
• Current issues when it comes to general insurance:-
• Key aspects of the product governance rule to include product value assessments;
• New rules on multi-occupancy insurances and the ramifications of this for insurers and brokers alike.

Speaker bio

I started my insurance career in 1987 and have worked across the sector including stints at PwC and GISC and have led my own consultancy practice since 2004 working closely with AMII, BIBA and the CII and have provided hundreds of well-received (even entertaining!) talks. I am a recipient of the Thomson Reuters Compliance Personality of the Year Award, the London Market People Award for Legal and Compliance and was Highly Commended in the CII Public Trust Awards in 2021. I am proud to judge various insurance awards and am always being approached for commentary and analysis.

I have been a regular speaker at virtually all of the CII’s local institutes and since the world went virtual I have provided over 200+ events to more than 15,000 insurance professionals and feedback has been superb:-

“Thanks for the webinar on Consumer Duty, Product Governance and Multi-occupancy insurances - personally I thought it was a fantastically informative session and the way you brought it to life was incredible. This could have been a very challenging topic to engage an audience of over 70 people on and it was anything but!” Adam Ross FCII, Ambassador for the Insurance Institute of London

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