Timeline
There were five key milestones for the implementation of the Consumer Duty rules, with a sixth milestone focused on adherence, ensuring continuous compliance and development moving forward.
1
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2
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3
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4
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5
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27 July 2022
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31 October 2022
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30 April 2023
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31 July 2023
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31 July 2024
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Final rules and guidance
published.
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Firms’ boards (or equivalent
management body) should have
agreed their implementation
plans and be able to evidence
they have scrutinised and
challenged the plans to ensure
they are deliverable and robust
to meet the new standards.
|
Manufacturers should have completed
all the reviews necessary to meet the
outcome rules for their existing open
products and services so they can
share with distributors to meet their
obligations under the Duty, and
identify where changes need to
be made.
|
Implementation deadline for new
and existing products or services
that are open to sale or renewal.
|
Implementation deadline for
closed products or services.
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Continuous Adherence
As part of our continuous adherence to the Consumer Duty, TAM places a high priority on the ongoing review and monitoring of products to ensure they continue to meet the needs of all clients. We recognize the importance of advisers regularly reviewing the suitability of TAM’s products for their clients, particularly in terms of risk profiles and any characteristics of vulnerability.
Advisers must ensure that suitability assessments and risk evaluations are continuously updated, reflecting any changes in their clients' circumstances. This is particularly important for clients with characteristics of vulnerability. Advisers should communicate with TAM if any adjustments are needed to better support clients, especially those who may be more vulnerable. This collaboration ensures that TAM, in its capacity as a Discretionary Fund Manager (DFM), can positively influence the client experience by adapting our approach where necessary.
In line with our governance practices, we have embedded Consumer Duty compliance as a static agenda item for regular review by the TAM Board. This ensures that Consumer Duty remains a central focus in our ongoing operations and product offerings. The board will review product performance, the suitability of products, and any necessary changes to ensure they remain in the best interest of all clients, particularly those with vulnerable characteristics.
Through regular communication and feedback, advisers help us meet the Consumer Duty by ensuring the fair treatment of all clients, including those who may be more vulnerable. By working together, we can ensure that our clients are receiving the best possible outcomes while adhering to regulatory requirements.