What is Consumer Duty?
The FCA introduced the Consumer Duty in July 2023 to improve levels of protection for retail customers. The Consumer Duty sets the standard of care that firms should give to customers in retail financial markets.
There is a new Consumer Principle – A Firm must act to deliver good outcomes for retail customers. Liontrust is committed to delivering against this new Principle 12 and this includes adhering to the cross-cutting rules across our online and manual customer sales journey and when working with third parties we must act in good faith towards our retail customers, avoid foreseeable harm to retail customers and enable our retail customers to pursue their financial objectives.
FCA Consumer Outcomes
There are four consumer outcomes:
- Products and services
- Price and value
- Consumer understanding
- Consumer support
Cross-cutting rules:
- Act in good faith toward retail customers
- Avoid foreseeable harm to retail customers
- Enable and support retail customers to pursue their financial objectives
Liontrust's approach to Consumer Duty
The below has been written on behalf of Liontrust.
Culture and strategy
The FCA has emphasised the importance company culture has on delivering good outcomes for the retail investor. We have a dedicated working group to ensure that our purpose, leadership, governance and people aligns with the Consumer Duty. Clients and investors are at the core of all our actions and decisions.
Our Consumer Duty Champion is Mandy Donald, who is a Non-executive Director (NED) of Liontrust Asset Management PLC and independent NED of the Liontrust Fund Partners LLP Management Committee.
How we plan to monitor outcomes
We use the Group Risk Scorecard system to measure levels of harm and confirm whether we have met consumer outcomes. Risk indicators show when an action should be considered. The output of this proactive and reactive monitoring approach is supplemented with additional reporting on Consumer Duty. We have also established a new Committee - the Consumer & Conduct Committee - that replaces our existing Treating Customers Fairly Committee. The Committee is structured around the four consumer outcomes, cross-cutting rules, and culture, conduct and competence.
Consumer understanding and consumer support outcomes
Liontrust is focused on providing communications and content that is understandable and accessible to all retail clients, including clients who may have characteristics of vulnerability. This includes educational articles which are being continuously added to our website.
Part of our focus is also expanding the literature that we produce for distributors to share with their clients. Liontrust has joined other asset managers to establish a consumer panel run by an independent research company. This is providing feedback on whether retail investors understand the communications, literature and content; what they find interesting and useful; and what else they want to be given and informed about. In addition, we have included a short survey on every fund page on our website for personal investors to provide further feedback. This will help us to make our communications as relevant and accessible as possible.
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We welcome feedback from distributors on our communications and literature.
Vulnerability and accessibility
We have made a number of improvements specifically around vulnerability and accessibility. These include:
- - Appointing three internal Vulnerable Customers Champions who have been specially trained.
- - Training on the Duty has been provided to ensure all Liontrust employees are aware of their responsibilities as part of their specific roles and how they are able to contribute to good customer outcomes. This included specific consideration of retail investors with characteristics of vulnerability.
- - Accessibility tools have been added to the website, please let us know if you or your clients require further help with accessibility.