Consumer Duty: The Distributor Data Challenge – Where are we now? 

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April 2023 was a key Consumer Duty milestone, when manufacturers should have completed all reviews needed to meet the outcome rules for their existing and open products and services to share with their distributors. The implementation deadline follows hot on its heels at the end of July. To help support member fund boards with the many and complex requirements of Consumer Duty, FBC has taken the temperature of how asset managers are progressing towards the more immediate requirements around distributor data in our latest FBC Research Note  

Our Research Note provides insights from both in-depth discussions with member firms and the wider industry. It brings together commentary from FBC’s Digital Meeting on this topic in April, in which Simon Hynes, FBC senior adviser, hosted the expert panel consisting of Laurence Mumford, Distribution Governance Director, M&G, Daniel Edwards, Head of Retirement and Wealth Product, Parmenion and Mandeep Bhandal, Senior Policy Advisor, The Investment Association, along with a poll of senior product and governance professionals, conducted in May 2023.  

Some of the key aspects of the discussion and poll explored further in the Research Note are: 

  • how the industry is facing up to the challenges 
  • the emergence of the European Mifid Template 4.1 and its position as a ’solution’ for Consumer Duty outcomes 1&2 
  • the end of July enforceable deadline and potential outcomes of joint trade body group discussions 
  • the expected impact of information-sharing on the relationship between asset managers and platforms 
  • insights about the challenges faced by platforms and their role as distributors 
  • examples of data items that could potentially provide useful feedback to help fund groups validate how well their product design and target market plans are working for consumers. 


FBC strongly believes that fund groups will need to think broadly and creatively to gather customer insight from a wide variety of sources. Much of this comes into firms already but to different departments and to meet differing needs. Data from platforms will give some of this but true actionable insight is going to take time to develop and be implemented. Over the coming weeks it will be interesting to monitor how distributors respond to the EMT 4.1 initiative and what traction the data/software vendors make. The approach taken by overseas fund domiciles is also increasingly relevant with most having UK-based investors who will therefore be subject to some elements of the consumer duty rules.  

Condensing all of this into a genuinely useful board pack will be a skill in itself. Consumer Duty board champions have been appointed but little support or specific guidance has come their way. 

FBC Corporate Members can now access the recording of the Digital Meeting and Research Note on-demand in the Member Portal. 


Forthcoming Consumer Duty support for FBC Corporate Members 

As part of FBC’s ongoing research and engagement on Consumer Duty, we are hosting a meeting specifically targeted at Consumer Duty Champions on 21st September 2023. Exclusive to FBC corporate members, invites will be sent in the coming weeks.