The latest log of wider implications issues that potentially affect large numbers of consumers, where there could be significant redress or where there is a risk of business failure identifies 5 recent, new and ongoing issues:
- the Consumer Duty – the key concern being that outcomes based regulation may lead to inconsistent interpretation of FCA rules, particularly as between the FCA and the FOS;
- APP scam complaints – and the need to make sure consumers are protected and provided with information;
- undisclosed commission – particularly in the motor finance sector and described as a “live, ongoing and fast moving” issue;
- cost of living – where there is a change of high numbers of vulnerable customers which emphasises the need for appropriate communications with those who need them; and
- advice/guidance boundary – a long standing issue, with the current law making it hard to create support for consumers with simpler needs.
