Recommendation 40

Firms have told us that uncertainty around the FCA’s expectations on the Consumer Duty , including over which markets and customers it applies to is causing them to take an overly risk-averse approach to complying with the Duty, adding unnecessary volume to an already high burden of compliance. The FCA must engage with firms to identify the key drivers behind this reaction. It must review the guidance it has provided on the Consumer Duty and identify where further clarification is needed of its expectations on how the Duty should be implemented.