The FCA has updated its resources on the Consumer Duty to confirm that, as of 27 February, it no longer expects firms to have a Duty champion, although of course they are free to have one. In the run up to the Duty’s implementation the FCA had expected firms to appoint a Board level champion to raise the Duty regularly in discussions and make appropriate challenges on how the firm was embedding it. Now that the Duty should be well embedded in all management discussions, processes and policies, the FCA wants to give firms more flexibility over their ongoing governance arrangements.
