In a webinar in December, the FCA warned companies that the regulations for closed book products were just as important as the current rules.
FCA director of cross-cutting policy and strategy Nisha Arora said: “Of course, there are some differences with closed products as they’re not on sale to new customers – you don’t need to identify your target market and you don’t need to develop a distribution strategy, but that doesn’t mean the duty is any less important for closed products.
“It applies fully, and you still need to do a thorough and ongoing assessment to ensure your closed products deliver the right outcomes and meet the requirements of [the] duty.
“For example, we don’t expect firms to consider the target market and distribution strategy for products that are no longer on sale. We will, however, still expect you to consider if closed products and services could lead to foreseeable harm or frustrate customers pursuing their financial objectives.”
In conclusion, the year ahead may prove more positive than the year we have left behind. Economic recovery may be slow but is expected to be stable and rates may start to ease.
But when it comes to advice companies, there is still plenty to prepare as the next 12 months will prove to be busy for big regulatory change.
carmen.reichman@ft.com