FCA Discussion Paper 25/3: Expanding Consumer Access to Investments - Which? Response

Which? welcomes the opportunity to respond to this discussion paper from the Financial Conduct Authority (FCA) and to share our position on expanding consumer access to investments.

Summary

• Any policy initiative designed to expand consumer investment first needs to be balanced against the need to ensure consumers’ financial resilience. 
• We are concerned that some current industry practices are falling short of the requirement to prevent foreseeable harm under the Consumer Duty.
• The FCA should urgently review the practice of Copy Trading, where we have found evidence of potentially misleading risk classification.
• We are concerned that the current self-certification process under the Financial Promotion Order (FPO) exemptions is substantially increasing the existing level of harm in the market.