11 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 Does not have any barriers to stop clients using its services? For example, it should be at least as easy to exit a service as it is to purchase it in the first place. • Platform due diligence checks for exit penalties. • Implementing an Advisory Board with client involvement to provide an opportunity for client input on the firm’s services. • Monitoring adviser/client ratios so that each adviser is able to properly service each client. • Contingency procedures are in place in the event that an adviser leaves the firm (especially a specialist adviser) to ensure continuity of client servicing. • Suitable business continuity processes in place to address loss of access to or evacuation from your offices, fire, flooding, extended loss of electrics or communications, loss of key staff, loss or damage to IT systems. • Clients are given opportunities to feedback or voice concerns. A complaints process is in place and complaints are handled within required timeframes. Can extend its PROD obligations to all retail products and services that clients may use? • Documented advice and admin process covering all products and services offered, such as an annual pension review process or mortgage review processes. • Providing staff training on how the scope of PROD rules differs from the scope of the Consumer Duty.
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