The Consumer Duty - Products and services

10 How to achieve FCA requirements Points to consider Can you demonstrate, with appropriate evidence, that your firm: Specific examples as to how to achieve this These examples will not be relevant to all firm types Makes sure that its charges for services represent fair value for clients? • Documented rationale in place for the firm’s charging structure clarifying how services are priced (for example, ‘cost plus’ and/or ‘value based’) to demonstrate the value of the firm’s services in tangible terms • Regular tests of the charging model by checking the time and cost to deliver different types of advice / service • Use of a fee cap or fee collar • A procedure is in place for recording the time spent with each client and confirming that each client is in the right service proposition • Records are kept of the ‘add-on value’ being provided by the firm in terms of generic information, for example, lasting power of attorneys, wills, trusts, generic tax tips and basic debt counselling Considers the requirements of all client segments and varies its charging structures as appropriate? • Apply different, easy to understand, charging structures to different segments of the client bank to limit cross subsidy • A periodic review that the services listed under each service proposition are relevant, can be easily understood and add value • Use client surveys or an Advisory Board to establish the service components that clients value most

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