Getting Ready for the Consumer Duty April 30th Deadline
“Manufacturers should have completed all the reviews necessary to meet the outcome rules for their existing open products and services so they can share with distributors to meet their obligations under the Duty, and identify where changes need to be made.” – FCA
Good news, at Mann Island, we are well on track to complete our manufacturer duty to undertake product reviews and provide our assessment to our dealer/broker introducers by the end of April 2023.
We’ve defined our products as
- Hire Purchase (HP)
- Personal Contract Purchase (PCP)
- Lease Purchase
Our product assessment includes:
- Details of the product and its rules
- Key features of the product
- Target market of the product
- End-to-end fair value assessment, including any commissions
- How we envisage working together
So what do such product reviews and assessments mean for dealers and brokers?
Armed with this information to comply with Consumer Duty requirements, we see the key responsibilities for our dealers/brokers in the finance distribution chain are to:
- Review our product assessments when they are received and consider whether they enable you to:
- understand our distribution strategy and target market for the products;
- consider the needs, characteristics and objectives of potentially vulnerable customers within the intended target market;
- understand the value the products are intended to provide to customers;
- assess whether your own distribution arrangements (including any remuneration you receive or pay and your distribution of any other product – for example, insurance – alongside our products) are consistent with our distribution strategy and the fair value of the products as we’ve assessed it.
We advise dealers/brokers to document this assessment in case it is required later. If, after reviewing our assessments, you feel you need further or clearer information, we are ready to discuss what we can do to help to ensure we meet our respective Duty obligations by the July 31st Consumer Duty implementation deadline. After all, isn’t that what a good partner should be doing?
I hope this latest article helps, and as promised, I will keep posting on the forthcoming Consumer Duty sharing our insights as the deadline approaches.