Consumer Duty - What does it mean for wholesale firms?

The FCA published its final rules on the Consumer Duty in a Policy Statement on 27 July 2022 (PS22/9) and firms now have until 31 July 2023 to fully implement such rules for new and existing products or services and until 31 July 2024 for closed products or services. 

Firms must establish implementation plans by October 2022.  This briefing discusses implications of the regime for firms engaged in wholesale markets whose products or services may be consumed by UK retail investors.  

A separate briefing: (i) summarising the basic requirements of the regime is available to download here and (ii) examining the implication to third-country firms and outbound services is available here

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This content was originally published by Allen & Overy before the A&O Shearman merger