Recommendation 182

Some witnesses told us that the uncertainty around the application of Consumer Duty had driven a risk-averse approach. Monzo told us: “Consumer Duty’s ambiguity drives risk-aversion” and “the lack of clarity around their application is prompting banks and fintechs to become increasingly risk-averse, fearing potential non-compliance.” 280 David Postings also told us that the Consumer Duty had reinforced risk aversion in firms, stating that “authorised push payment fraud and the consumer duty” are “two really significant ones which cause us to have a very risk-averse approach, with a lot of protection for consumers, which can actually end up with consumer detriment.” 281