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Get ready for PS22/9 – Part 1: The new Consumer Duty highlights old challenges

Explore the barriers that are preventing financial services providers from achieving compliance with the FCA’s new PS22/9 Consumer Duty.

Explore the barriers that are preventing financial services providers from achieving compliance with the FCA’s new PS22/9 Consumer Duty.

consumer duty



14th December 2022

Kevin Phillips

In a world of mounting consumer demands, some financial services organisations have struggled to provide the level of service their customers expect, and this has led to the FCA creating a new Consumer Duty, known as PS22/9.

Designed to ensure better outcomes for retail customers, the FCA explains that PS22/9 will “set higher and clearer standards of consumer protection across financial services and require firms to put their customers’ needs first”.

With the financial services sector diversifying at every level, from nimble FinTech entrants disrupting the status quo to giant incumbents embracing the age of digital banking, customers relationships with their providers is changing. People are more fiscally aware and engaged with their finances than ever before, for a wide variety of reasons. On the one hand, DIY investing is on the rise, but on the other, the growing cost of living crisis is leading to consumers watching their spend more closely.

And because people are more engaged, gaps in service provision have started to show. PS22/9 aims to combat that, ensuring everyone is supported fairly by their financial services providers.


New rules for service, clarity, and support

In July 2022, the FCA set out its final rules for PS22/9. The Duty affects every type of firm covered by the FCA’s principles of business, ranging from traditional financial services providers such as banks and investment firms to more the recently regulated group of PIs, EMIs, and RAISPs.

The overarching principle is to deliver better consumer outcomes by following three rules: act in good faith, avoid causing foreseeable harm, and support customers to achieve their financial objectives. These rules should be applied to products and services, price and value, consumer understanding, and consumer support—so efforts span the whole environment.

The deadline for implementation plans passed at the end of October, with leaders required to outline how they plan to achieve compliance within their organisations. The Duty will ultimately come into force in phases; 31st July 2023 for products or services that are open to sale or renewal, and a year later for closed products or services.

However, there’s a major stumbling block in PS22/9’s roadmap. Less than a quarter of firms report that their current services are compliant, which means there’s a massive amount of work ahead for the majority of providers. More concerningly, over half of regulated firms say they likely won’t be compliant with the Duty by the deadline—and most don’t have a solid plan in place for achieving compliance, either.

Barriers to compliance

So what is preventing these organisations from meeting the FCA’s demands? Each organisation will experience different challenges over the next few months, but here are some common issues to look out for:

It’s a significant cultural shift

The first major challenge is highlighted by the FCA itself in its guidance for PS22/9: this is likely to be “a significant shift in culture and behaviour by many firms”—and those don’t happen overnight.

Organisations lack the required capabilities

Particularly in large institutions, there’s often a complex infrastructure of data silos, point solutions, and disconnected teams to contend with. Though many financial services providers consider themselves digitally enabled, commonly used core banking-focused tech solutions won’t cut it for experience-focused requirements.

The requirements aren’t clear to everyone

Understanding is also proving to be a barrier for some organisations. Around 10% say they don’t have a complete understanding of what the Duty expects of them, so it’s difficult for them to prepare effectively. The FCA is running events in the coming year to help educate teams on the rules and the best approach to achieving compliance.

Teams aren’t making the most of their data

Many firms aren’t making best use of the data they have, especially when it comes to defining and servicing the “average customer”. The Duty has a more specific focus on the needs of individual customers, especially when it comes to any potential indicators of vulnerability—this is when data and personalisation tools will come into their own.

Checklist 2

PS22/9 will be a challenge—but there’s opportunity here too

Working towards PS22/9 compliance will be a big challenge for many organisations. But it’s also a great opportunity for leaders to take advantage of the external pressure and accelerate key improvements to the customer experience, core systems, and collaboration processes.

In part two of our Get ready for PS22/9 series, we’ll be highlighting some of the key steps leaders can take to achieve compliance—and how our own Interact Application Suite can help.

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