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The FCA’s Consumer Duty – higher and clearer standards with positive outcomes for consumers

By Laurence Pipkin, ACII, Chartered Insurance Underwriting Agent, Managing Director

(Estimated reading time: 2 minutes 46 seconds)

The FCA’s Consumer Duty came into force on 31 July 2023. Its aim is to set higher and clearer standards in order to provide positive outcomes for consumer and protect them from financial harm. Above all the intention is for firms to put customer needs first.

The new consumer duty requires firms to act to deliver good outcomes for retail customers by providing greater clarity on the FCA’s expectations and helping firms interpret the four outcomes:

These relate to products and services, price and value, consumer understanding and consumer support and each is looked at a little more closely below.

FCA authorised firms such as Temple have embedded the principles of treating customers fairly and conduct risk into our values, processes and governance for many years. These principles have ensured fairness and protection for customers. However, we recognise the consumer duty sets a higher bar which ensures that all firms at every stage of engagement should be posing themselves the question ‘Is this the right for the customer?’

It is clear that distributors of insurance products must consider the following areas in conjunction with the four outcomes:

  • Products and services – Intermediaries should understand the products and services, target market and their role in the distribution chain to the end customer
  • Price and value – Intermediaries should be clear on their role in the distribution chain and that their contribution and cost to the customer represents fair value in the light of the product provided.
  • Consumer understanding – ensure customers understand the product provided throughout the product lifecycle
  • Consumer support – provide accessible clear support to customers throughout the product lifecycle.

Underpinning all aspects should be a commitment to identifying and supporting vulnerable customers and they should be considered in all parts of the product life cycle,

By now, all regulated firms should have made the necessary changes to ensure compliance with the new consumer duty however the FCA have communicated their concerns to the insurance industry via a series of portfolio letters

The FCA’s concerns are focused predominately on the price and value aspect of the new consumer duty which also covers changes to product governance in this area during recent years. Specifically the FCA is concerned with the extent firms have implemented these rules relating to the value of products and services overall. The FCA is also concerned whether firms are able to show that their value assessment of those products is in line with FCA expectation.

The FCA are also concerned that their own investigations and information received thus far has shown weaknesses in product governance activities and a lack of adequate management information.

Finally in a webinar hosted by the FCA last week the regulator made very clear the consumer duty is not a “once and done” job and must be continually reviewed by regulated parties to ensure we all deliver the expected positive outcomes for our customers.

There appears much work to be done across the industry to ensure that the new consumer duty is being applied effectively and the bar has indeed been raised in the insurance industry and wider applicable financial services.

Temple is here to support intermediaries that provide our products please get in touch if you have any queries in relation to our product to improve you understanding of their benefits and value to customers. Please call my colleague Sarah Steer on 01483 514874 or send an email to her at

Laurence Pipkin

Managing Director
Read articles by Laurence Pipkin

Laurence Pipkin

Laurence started at Temple Legal Protection in 2006 where he was IT Manager until 2017, when promotion to Operations Director saw him join the board of the company. This was followed in June 2019 with his appointment as Managing Director to succeed Chris Wait, the founding MD. Following in those footsteps was a challenge relished by Laurence, and one with the full support of Chris, who became Chairman of the board of directors.

Laurence’s hands-on experience at the heart of the business running the IT systems over many years and his proven expertise in a fast-moving ATE/litigation insurance market has contributed to the respected position in the market place Temple now occupies.

Resting on laurels is not Laurence’s style. His passion and determination to provide market-leading legal expenses insurance products and a total commitment to customer service for partner law firms and brokers put him in the ideal position to lead the business.

Prominent litigators, contemporaries and colleagues speak of Laurence’s sound commercial judgement, technical excellence and agility in product development – all backed by a commitment to robust underwriting principles. This has led to Temple building long-term commercial relationships with leading law firms in the commercial litigation, clinical negligence and personal injury sectors.

Laurence is a Chartered Insurance Underwriting Agent, and associate member of the Chartered Insurance Institute.


Read articles by Laurence Pipkin