Recommendation 180

We heard from witnesses representing wholesale business and specialist service providers that the Consumer Duty duplicated pre-existing fiduciary duties and other regulatory requirements that govern their relationship with clients. They told us that this introduced either additional compliance, or new requirements to evidence pre-existing duties. State Street told us: “Some market participants (e.g., asset managers) were already subject to comprehensive regulatory requirements that outline their clear fiduciary duties, so it was not only unclear as to why the new framework was necessary but also resulted in significant work to understand and embed the Duty where it applied.” 277 The Lloyd’s Market Association told us: “Much of the specialist and international business written by the London Market is brought into Consumer Duty despite being covered by local consumer protection rules or where customers are advised by brokers acting on their behalf.” 278