FCA publishes final guidance on the fair treatment of vulnerable customers

On 23 February 2021, the FCA published its guidance for firms on the fair treatment of vulnerable customers.

From a Training & Competence perspective firms need to ensure their staff have the appropriate skills and capability to recognise and respond to the needs of vulnerable customers.

The guidance goes on to provide examples of how some firms have worked with a variety of organisations to help increase the understanding of front-line staff to the needs of vulnerable customers.

Clearstep believe of equal importance is the defining of competencies and standards required for all staff in order that vulnerable customers experience good outcomes and receive consistently fair treatment.

FCA publishes consultation paper on their approach to regulating the Funeral Plans sector

On the 2nd March 2021 the FCA published Consultation Paper 21/4 on their proposed approach to regulating the Funeral Plans sector.

For those with an interest in Training & Competence the proposals are pretty much as expected – firms need to demonstrate their employees have the appropriate knowledge and competence, are of good repute and a minimum of 15 hours training and development is undertaken per year.

Firms affected should not underestimate the timelines required to define their customer journey, design, and deliver the associated training, as well as developing their people policies and frameworks accordingly.

Find out more here: https://www.fca.org.uk/publication/consultation/cp21-4.pdf


Clearstep Consulting is facilitating the live learning event ‘SMCR: Getting your fit and proper assessments right first time’ for PIMFA on Monday 22nd February 2021 at 9.30 am.

By the 31st March 2021 solo regulated firms under SM&CR will have to ensure that certified staff are fit and proper (F&P) to do their roles. This is your last opportunity to ensure that your firm’s managers and supervisors get the F&P assessment of your staff right first time, particularly in the area of assessing competence and capability.

This event is open to members and non-members. Please click here to find out more and register https://www.pimfa.co.uk/event/pimfa-live-online-learning-smcr-getting-your-fit-and-proper-assessments-right-first-time-2/


Employees First, Customers Second: Turning your approach to T&C upside down in 2021.

Lynne Hargreaves of Clearstep Consulting will be joining Adrian Harvey, CEO of Elephants Don’t Forget for an exclusive new webinar on the 24th February at 10.00 am.

We will be discussing why a more robust approach to T&C in 2021 will be critical for regulated firms looking to enhance consumer trust in the brand.

In this webinar you’ll learn more about:

  • How consumers have redefined the rules of engagement.
  • The role of T&C in the new reality.
  • T&C comply or compete, the choice is yours.
  • The relationship between T&C, culture, brand and financial performance.
  • Choosing how and when to assess your employees.

Please click here to register https://info.elephantsdontforget.com/webinar-registration-employees-first-customers-second


FCA publishes Consultation Paper CP18/26 on applying SM&CR to Claims Management Companies

On the 1st April 2019 the FCA will become the regulator of claims management companies (CMCs). At the same time the Financial Ombudsman Service will become responsible for resolving disputes about CMCs.

The FCA is now consulting on how the Senior Managers and Certification Regime (SM&CR) will apply to CMCs. The consultation paper sets out the proposed rules about when SM&CR may apply to CMCs and what action firms will need to take.

There is also a consultation ongoing with regards what fees the FCA proposes to charge CMCs.

Please click here for:

FCA consultation paper – SM&CR for CMCs  https://www.fca.org.uk/publication/consultation/cp18-26.pdf

FCA consultation paper – Fees for CMCs https://www.fca.org.uk/publication/consultation/cp18-23.pdf

FCA support website page for CMCs https://www.fca.org.uk/firms/claims-management-companies

FCA Publishes Policy Statement PS17/21 – Insurance Distribution Directive Near Final Rules

This Policy Statement from the FCA provides their response to the feedback received to CP 17/7 on the IDD. It also sets out the near-final rules with regards application, professional requirements, complaints handling and ICOB. For those with responsibility for T&C, please note it introduces the completion of 15 hours CPD each year for relevant staff, some of whom might be Retail Investment Advisers where the 35 hours composition has changed.

Firms are required to comply with these new rules by 23 February 2018. Please click here for:

FCA Policy Statement https://www.fca.org.uk/publication/policy/ps17-21.pdf

IDD – What’s it all about https://www.trailight.co.uk/idd-whats-it-all-about/#more-544



BSB Publishes Certification Regime, Fitness & Propriety Guidance

In February the Banking Standards Board published a statement of good practice and supporting guidance on implementation for the assessment of fitness and propriety of those within the certification regime.

Please click here to download:



CP 17/7 – Insurance Distribution Directive Consultation Paper

This Paper from the FCA consults on changes to the SYSC, TC, MIPRU, IPRU(INV), ICOBS and DISP sourcebooks. It looks to enhance competence by introducing knowledge and ability requirements to be demonstrated by completing 15 hours of CPD a year. A must read for those involved in insurance and reinsurance, intermediaries and other firms in the insurance market – https://lnkd.in/gi_fndW