Mark Lee & Teja Picton-Howell assess the impact of the Consumer Duty on travel insurance products & distribution
- The FCA’s Consumer Duty takes an outcomes-based, rather than box-ticking, approach.
- Includes suggestions to help firms understand and comply with the new approach.
- Looks at the two most common consumer complaints for legal expenses exclusions.
The Financial Conduct Authority’s (FCA’s) ‘new’ Consumer Duty is no longer so new. The rule has been in force for sales of ‘open’ products and services since 31 July 2023, and applies to ‘closed’ products and services from 31 July 2024.
Much commentary and guidance has been published about the Consumer Duty, including helpful updates on its implementation by the FCA, giving examples of good practice and areas for improvement. We need not, therefore, go into any detailed analysis of the scope of the duty here, because this is already widely available. Instead, we will focus on the impact of the duty on travel insurance products and distribution.
What it is
The Consumer Duty is the rule that ‘a firm
