FCA Call for Input on Review of FCA requirements following the introduction of the Consumer Duty - Which? response

Our response focuses on whether the FCA can simplify requirements. We make the following key points:

• It's too soon to undertake this review. The Consumer Duty has only been introduced for a short time. There has been no formal or comprehensive review of its impact, meaning that it is premature to consider how it might replace detailed rules.
• In general, the Consumer Duty should be seen as complementing rather than replacing detailed requirements. However, where duplication or contradictory requirements between the Consumer Duty and specific rules are found, the FCA should assess them on a case-by-case basis rather than seeking to delete them and assuming that the Consumer Duty can fill any gaps which may emerge.
• Removing detailed rules, unless clearly no longer relevant, would represent a reduction in enforceable consumer protections that is not warranted, and has the potential to undermine consumer trust and confidence.