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Continuing Consumer Duty insight series

Consumer Duty & the FCA’s: ‘Use it or Lose it’ initiative 👋 – Part 5 of this 6-week series.


Given the introduction of the Consumer Duty principle with the FCA’s continued focus on reducing consumer misunderstanding, being misled about exposure to financial risk, and the level of consumer protection in place, what practical steps should Firms take to ensure they do not fall foul of the FCA’s continued focus of its “use it or lose it” initiative?


Firms should implement a continuous review of current regulatory permissions to ensure they are up to date and apply for variation of permissions where necessary.


During this review, Firms must assess and evaluate their product range and business proposition within the context of their current permissions and against any future strategic development. Correspondingly, Firms must also consider how changes from the regulator can also impact applicability.


Across its regulatory perimeter, a Firm should look at the entirety of a given standard or process as described within the FCA Handbook and consider each regulation type; rule, guidance point, and evidential provision in turn and assess its applicability to the firm.

Whilst in scope regulation is relatively straightforward to assess and provide rationale for, Firms must also give due consideration to sourcebook content that doesn’t apply and provide a justification for this.


By incorporating this process into an overarching compliance monitoring framework, changes to product, business model and the operating environment, the Firm will be in a stronger position to evidence its adherence to the threshold conditions and in turn demonstrate effective oversight and governance of its business activities.


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