The BSA is delighted to have the opportunity to contribute to the FCA’s review of requirements following the implementation of the Consumer Duty. We agree that a thorough review, followed by action to address the findings of that review creates a welcome opportunity to help ensure that FCA regulation remains effective, streamlined and comprehensible, maximising the Duty’s benefits.

We have consistently highlighted our concerns about the potential for the introduction of the Consumer Duty to lead to confusion and overlap. We are pleased to see that the FCA are now exploring the potential to take action to simplify things for firms and consumers.

In this response to the FCA’s Call for Input, we provide feedback on rules that should be reviewed and the potential benefits of doing so.

As the FCA’s work in this area continues, we encourage the FCA to allow firms sufficient time and opportunity to consider and provide information to them directly on the likely costs and benefits of any proposals that may be taken forward.

While this review has been prompted in large part by the Consumer Duty, we are particularly pleased to see that in its Call for Input the FCA is looking more widely. Using this as an opportunity to seek further input to understand whether, where and how current requirements might be simplified through greater reliance on high-level rules, while ensuring consumers continue to be supported and protected is entirely appropriate and very welcome.

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