The Consumer Duty - Products and services

13 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 Monitors its services to make sure they remain consistent with the identified target market(s)? • Identify a client each month to ensure that the characteristics are within one of the firm’s identified segments and the products and services meet their needs • Senior manager monthly random checks to assess whether the firm’s review process has been followed and the client has obtained the correct product and service outcome • Monitoring Adviser KPIs to ensure annual reviews are being delivered in line with the client agreement Has transparent charging structures? • Use client surveys or an Advisory Board to test clarity of the firm’s charging structures in its client agreement and other marketing material • Apply different, easy to understand, charging structures to different segments of the client bank to limit cross subsidy • Document any concessions on investment advice fees, which are signed off by a senior manager and reviewed in Board meetings • Publish the firm’s charging structure on its website • Provide regular training and T&C assessments to ensure all advisers can explain the firm’s charging structure correctly

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