The end of January marked six months on from when the FCA introduced its principles-based Consumer Duty to support good outcomes for all.

To gather a sense of how advisers are embedding the rules into their firms and the areas they’re finding more challenging to meet, we carried out a short survey with the help of 300 adviser firms.

While I anticipated some parts of the Consumer Duty to stand out as taking up more of firms’ time and attention than others, our research results indicate that advisers’ efforts are evenly spread across all aspects of the rules.

This is interesting.

Every firm reported back to us that they’re focussing on one or more aspect of the rules. It’s a clear indication that advisers are continuing to prioritise embedding the Consumer Duty into their businesses. The fact that they’re as likely to be working on any of the four outcomes highlights how each firm is individual, coming up with their own strategies to ensure compliance.

The regulator wanted the industry to take all parts of the Consumer Duty seriously. Our findings that there’s widespread variance in firms’ priorities is evidence of the advice sector doing exactly that.

The Price and Value outcome remains interesting

Out of the four Consumer Duty outcomes, Consumer Support is the one that the advisers are most focused on (44%), but this result is closely followed in order by Consumer Understanding, Products and Services and Price and Value (all above 30%).

Although our results are only a sample of current adviser sentiment, I was interested to see Price and Value appear with the lowest score.

Before the rules were put in place, I anticipated that demonstrating value for money and documenting whether total costs to clients provide ‘fair value’ could be one of the more onerous parts of the Consumer Duty to meet. Advisers know that clients value their service, but providing evidence is another matter.

However, our findings reveal that Price and Value is the outcome with the largest variance in responses depending on the adviser firm type - direct authorised firms rate the outcome second highest on their list of priorities. In conclusion, all four Consumer Duty outcomes continue to be important areas of focus for firms.

Preparation is standing advisers in good stead

A key takeaway from the survey results is that six months on, not only are all firms prioritising something to meet the Consumer Duty, they’re taking steps and reviewing processes to help maintain compliance.

Our findings highlight a long list of potential actions by firms, including 19% focused on improving how they gather client feedback, while 18% are looking at improving or introducing new systems to capture management information (MI) or, separately, reviewing customer communications.

It’s really encouraging to observe such a big focus from firms on using their MI as a tool to self-assess areas of risk and foreseeable harm, and to measure progress, as this is exactly what the FCA want to see.

When quizzed about the type of MI being gathered, the top responses are:

Taking such a detailed approach to compliance and using data to measure against the four Consumer Duty outcomes is important for one other reason.

With its Consumer Duty, the regulator is now holding all sectors across financial services to the higher standards.

Over the past six months, the FCA has already identified its areas of concern in some industry sectors and has intervened in a series of direct ‘Dear CEO’ letters, most recently to wealth management firms.

The fact that our survey results indicate that the advice sector is taking the Consumer Duty seriously and are working hard to comply, will stand the industry in good stead when the regulator decides to send a ‘Dear CEO’ letter to adviser firms.

The principles of the rules should be foremost

With the Consumer Duty six months old, our research results show how there’s a clear opportunity now for adviser firms – including their partners – to share learnings and successes, and to take hard-won solutions and apply them to ongoing issues and concerns.

We may even see the FCA pick out and share examples of best practice in the industry and point to where to prioritise efforts in terms of bedding in the Consumer Duty rules.

For me, while advisers’ focus are evenly spread across all aspects of the Consumer Duty as our survey results indicate, to really align with the spirit of the rules, and to do so efficiently, firms should also be testing themselves against the big picture – the goal of delivering good outcomes for their clients.

Keeping the principles of the Consumer Duty front of mind will help all adviser firms to minimise the risk that progress towards the overarching ambition of the rules is lost by the obligatory processes.

See Adviser Insights for more of Alastair Black’s blogs and visit our Consumer Duty Support Hub for further help with the rules.

The value of investments can go down as well as up and your clients could get back less than they paid in.

The views expressed in this blog should not be regarded as financial advice.