Consumer Duty

The FCA’s consumer duty is part of the regulator’s ongoing efforts to enhance consumer protection in financial services. Consumer duty is a set of rules and principles that financial firms must follow to ensure they act in the best interests of their customers.

At Talbot and Muir it has always been our mission to help our customers thrive in retirement by providing flexible products and a personal cradle to grave service to meet their needs throughout their journeys with us, so the principles of consumer duty are not new to us.

This page provides our financial advisers with a high level overview of what Talbot and Muir is doing to implement consumer duty, and when you can expect key documents to be available.

Our financial advisers have a key role to play in meeting the requirements of Consumer Duty, as you provide advice and recommendations to consumers on financial products and services.

Four Outcomes

The ‘four outcomes’ are a suite of rules and guidance setting more detailed expectations for firm conduct in four areas that represent key elements of the firm-consumer relationship:

Products and Services Our products are designed to meet the needs of, and are distributed to, identified target markets.
Price and Value Ensuring our products represent fair value throughout the product and customer lifecycle.
Customer Understanding Our communications, support and enable customers to make informed decisions. They are given the information they need, at the right time and are presented in a way they can understand.
Consumer Support We provide a level of support that meets customers’ needs, enables them to benefit from the products and services we provide, and helps support them achieve their financial objectives.

Cross Cutting Rules

Consumer Duty requires firms to ‘put consumers at the heart of their business and focus on delivering good outcomes for customers.’ It introduces a set of cross-cutting rules focusing on three key behaviours which require firms to:

• Act in good faith towards customers
• Avoid foreseeable harm to customers
• Enable and support customers to pursue their financial objectives

Key Dates and Deliverables

30 April 2023 – We completed the manufacturer reviews necessary to meet outcome rules for all existing open products and services. The results of these have been shared in our Target Market Documents (see below) to help financial advisers (distributors) meet their obligations and identify if and where any changes need to be made.

31 July 2023 – Meeting implementation deadline for new and existing products.

31 July 2024 – Meeting implementation deadline for closed products

Target Market Documents

Target Market Documents are designed to ensure that our products are targeted appropriately, and to avoid offering unsuitable products to customers. By providing our advisers with clear and detailed Target Market Documents, we can collectively ensure that our mutual clients have products that meet their needs and expectations.

Listed below are the Target Market Documents for our current product:

The Talbot and Muir SIPP Target Market Document
Talbot and Muir SIPP Consumer Duty Q and A

Useful Links

The following links provide additional detail from the FCA on Consumer Duty:

The FCA Page on Consumer Duty
The Finalised Guidance from the FCA
Consumer Duty – information for firms