TAM is preparing for the Consumer Duty as a Manufacturer ahead of the end of April deadline
The Consumer Duty, which comes into force at the end of July, is a significant regulatory change that aims to set higher and clearer standards of protection across financial services, and to ensure that good consumer Outcomes are at the heart of firms’ strategies and business objectives and considered at every stage of the consumer journey.
As part of the implementation process and by the end of April, Manufacturers that are in scope for any of their products and services are required to have completed their reviews needed to meet the outcome rules and identified if any changes are required so they can share relevant information with Distributors. All firms, regardless of whether a Manufacturer or Distributor (or both) have until the end of July to implement these changes.
The four Outcomes are:
a) Product and Services
b) Price and Value
c) Consumer Understanding
d) Consumer Support
In the context of the 30 April milestone, TAM confirms that it considers itself in scope of the regulation as a Manufacturer of its discretionary managed range of model portfolios and Global Multi-Asset Fund, and has been working hard to ensure the necessary reviews have been undertaken. In that context we have taken the opportunity to make amendments to some processes, reviewed potential and foreseeable harms across the business and undertaken price and value assessments across the service range.
The completion of reviews and subsequent sharing of relevant information should allow Distributors to take comfort that the Manufacturer is acting to deliver good outcomes and adhering to the Cross-cutting Rules.
The information provided by Manufacturers is a key step in enabling Distributors to work out all aspects of the value chain and we are happy to engage with Advisers about the work undertaken.
From the beginning of May you will be able to access the relevant information regarding the work we have undertaken in a suitably abbreviated form on the TAM website here. We anticipate that this will both provide comfort and support your own price and value assessments.
TAM will continue to monitor and develop its review of all requirements under the Consumer Duty regime and look to implement further enhancements as required. This is not a “one and done” exercise and we will continue to seek ways to improve the consumer experience.
In the context of our requirements under Consumer Duty and our endeavour to ensure our clients' needs are at the core of everything we do, we are delighted to have recently featured in a DFM satisfaction study undertaken by Defaqto, an independent third party, which rates our standing within the DFM industry based on feedback provided by adviser firms. Whilst acknowledgement like this is not definitive and we won’t be resting on our laurels, we hope this provides some additional comfort regarding the level of service and support provided by TAM. The study was published in February and you can download the full report below, along with a simplified infographic we hope you find useful when discussing the topic with your clients.
As you are no doubt aware, co-operation and information sharing between firms across the distribution chain is a key area of focus for the FCA and a fundamental element in achieving the objectives of the Consumer Duty. We look forward to working together on this journey and sharing any relevant information to ensure we are working toward a shared goal of acting to deliver good consumer outcomes.
If you would like any further information about our approach to the Consumer Duty, or to discuss our discretionary investment management services in general, please do not hesitate to get in touch with us today.