Executive summary:

• Consumer responsibility (question 1): We note and support the FCA’s continued acknowledgement that  consumers have responsibilities, but we appreciate the fact that there are circumstances where consumers cannot be expected to take responsibility. We would welcome further engagement, across all relevant parties, on the important subjects of consumer rights, responsibilities, and financial education.
• Vulnerable customers (question 2): We strongly agree that building societies and other financial services firms have a regulatory and a moral responsibility to support customers who have particular needs and are at particular risk of harm. We suggest an appropriate framework for applying this responsibility. 
• FCA remit (question 3): Regarding the question about the FCA’s remit, one of the failings of the FSA was loss of focus - the FCA has clear statutory objectives and, in our view, should adhere to them. 
• Well-functioning market (question 4): There is much to support in the FCA’s vision for a well-functioning market that works for consumers, although we make an observation about the risk of conflating the concepts of inclusion and vulnerability – they can overlap but are not identical.
• Metrics for good consumer outcomes (question 5): We suggest that, from a regulatory standpoint, the two key requirements for good consumer outcomes are (1) a properly functioning competitive market, and (2) clear and sensible consumer rules that are properly enforced. Therefore, we suggest that metrics that the FCA might use should focus on ensuring that 1) and 2) are effective in practice.
• Additional or alternative factors (question 6): We appreciate that the FCA should engage with wider government policy where appropriate to do so. However, in its work designed to tackle “areas of greatest harm”, it is important that the FCA does not seek to place inappropriately wide responsibilities on the firms that it regulates.

Read the full response here.