Consumer Duty: we’re all in it together

The FCA’s first consultation for their proposed Consumer Duty regulation, due to be introduced in 2022, closed in July and in December it issued feedback and a second consultation document, with a deadline of 15 February 2022 for responses. The 243- page document lays out details about what the regulator wants to do and what is driving them to do so.

Firstly, we all need to recognise that this is not a simple refresh of Treating Customers Fairly. It will go much further than that.

Secondly, the onus to get it right in terms of the customer experience is across all areas of financial services. Being an adviser and in the front line of providing a service to consumers doesn’t mean the spotlight only falls on you – the FCA wants to see the entire value chain step up and take responsibility for changing things for the better.


What is PortfolioMetrix doing?

We have always put the end investor at the heart of our proposition. Regardless of how large we grow as a firm, we never forget that those assets are derived from individuals, putting their trust in us to do what we promise. to the best of our abilities.

However, this doesn’t mean we are complacent when it comes to the new regulation – far from it. We are already looking at where we can improve.

The consultation set out three consumer principles:

  1. Act in good faith
  2. Take all reasonable steps to avoid foreseeable harm to consumers
  3. Take all reasonable steps to enable consumers to pursue their financial objectives


With regard to these, all three go to the heart of our values and vision. We are an independent, privately-owned firm so we don’t have to indulge in practices that are solely designed to maximise corporate profits, regardless of whether this is in the best interests of investors.

As I’ve said, we have many family members, friends and colleagues invested with us. Knowing this, in addition to our corporate values, means we are highly motivated to ensure we avoid any “foreseeable harm”.

Risk management is at the heart of our proposition and we ensure we offer a range of portfolios that enable investors to pursue their own specific financial objectives. Importantly, we have developed tools that enable financial advisers to accurately identify and align their clients’ risk appetites with our portfolios.


Four outcomes

The FCA listed four outcomes in their consultation document. These “represent the key elements of the firm-customer relationship: how firms design, sell and service products and services, and the key contact points along the customer journey.”

The outcomes are:

  1. Communications
  2. Products and Services
  3. Customer Service
  4. Price and Value


Each of these elements is taken into consideration when we design our products and services. Taking a retrospective spotlight on how we’ve worked in the past, we are confident we can put a tick against all four of these outcomes.

We constantly evolve and review our processes and we will ensure each of these outcomes is an agenda point for the work we do as we continue to grow and develop.



Above all else, what the FCA is trying to do with this new regulation is to improve trust across financial services.

We take a strong stance on governance: integrity and transparency are central to our values and this is how we build trust with both advisers and end clients.

We are ever mindful that trust cannot be bought, it has to be earned.

No doubt advisers will be subjected to a barrage of hyperbole from providers and suppliers as the regulation comes into force. While words are easy to say, it’s by engendering long term trust that the financial industry and the advice profession will build a solid foundation with consumers.

Such a goal is in the interests of everyone so there’s never been a better time to work together for the greater good.