7 How to achieve FCA requirements To help threesixty client firms record their approach to the proposed new Consumer Duty an action plan is available covering the entire Consumer Duty framework, including its principle, three cross-cutting rules and four outcomes. Our action plans can be used either in conjunction with our comprehensive online guidance, or alongside the information available within our shorter downloadable guides, to prompt your thoughts on how your firmwill be able to demonstrate that you put your clients at the heart of your business, offer products and services that are fit for purpose and which represent fair value. On pages 9 to 13 we include an extract from the products and services section of our action plan. It includes questions that you can use to self-assess your current position in meeting the FCA proposed requirements. We have included some examples of evidence that may be relevant to demonstrate that your firm is meeting a particular requirement. The points noted are not exhaustive and depending on your firm’s activities and business model, you may need to consider other areas. It’s important to critically asses your current position and make sure that any evidence documented reflects what it happening in practice. Where more work is needed, our action plan includes space to document capture where action is still required. The product and services outcome complements the other outcomes. It is critical that products and services are well designed and targeted appropriately so that they can then be offered at fair value, suitably communicated and supported throughout their full lifecycle. threesixty comment A sample of our full template action plan is available on request, covering the ‘Comsumer Principle’, ‘Cross Cutting rules’, and the ‘Products and services’ outcome is available on request from our website. To request this sample, email talktous@threesixtyservices.co.uk
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