The FCA’s proposed Consumer Duty – implications for investment management firms

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Preparations for the introduction of a new Consumer Duty by the FCA are now well advanced. The second consultation paper, published last December, gives a clearer outline of the intended scope of the Duty and its associated obligations. Given its intentionally broad application to retail and wholesale business across the product distribution chain, and the current proposed implementation period of just nine months, firms should begin considering how the Duty may impact their business as early as possible.

This webinar will consider the structure of the Duty, its likely application to investment management firms and the steps firms will need to take to operationalise the proposed rules and guidance. 

Mandeep Bhandal, Senior Policy Adviser, The Investment Association
Mandeep joins us from the FCA having gained extensive experience in policy and regulatory affairs over eight years. Her roles involved managing and influencing a broad network of domestic and international stakeholders at senior levels.
She was the lead in working with the IMF on the UK’s 2021 IMF Financial Sector Assessment Program, helping to devise and deliver a strategy for a fair and positive assessment on the UK regulatory framework. She also spent a number of years leading the engagement with IOSCO, the global standard setter on capital market issues, advising the FCA CEO and senior leadership team and developing key relationships with international regulators. In addition, Mandeep worked on financial stability issues, leading the FCA’s engagement with the UK Financial Policy Committee at the Bank of England.

Sara Cody, Knowledge Counsel, Linklaters
Sara is a Knowledge Counsel in Linklaters Financial Regulation team specialising in UK contentious regulatory work. She has experience of all aspects of regulatory enforcement work and has written extensively on both FCA/PRA enforcement decisions and UK, EU and global enforcement trends. Sara leads the development of Linklaters’ thought leadership and horizon-spotting work in this area, focusing on publications and podcasts comparing the approach of national financial regulators across the globe to enforcement issues and relevant developments. More recently, she has also assisted several organisations responding to FCA and government consultations concerning proposed changes to regulatory policy.
Sara works closely with clients, equipping them to understand the impact of FCA/PRA investigations and enforcement action on their business and providing innovative training and other solutions to enable them to respond. She has taken a particular interest in the FCA’s development of its proposed Consumer Duty, leading on a series of Linklaters podcasts and publications analysing specific aspects of the proposals across a broad range of perspectives

Raza Naeem, Counsel, Linklaters
Raza has considerable experience in advising trading venues, sell-side and buy-side clients on a variety of regulatory topics including ESG, governance, wholesale and retail conduct, Fintech and market structures, and is considered to be an expert in his field. He also works closely with the broader Linklaters practice areas providing regulatory coverage on derivatives, structured products and corporate matters. Most recently, he has been advising clients on the new ESG reforms as well as the technical FCA/PRA Brexit onshoring rules and the impact on their business in areas such as MiFID II, MAR, PRIIPs and the short selling regulation. He is also the chair of the Linklaters global ESG working group.