Since March 2020, the Financial Conduct Authority (FCA) has been providing packages of measures across a range of products to assist customers who may be experiencing financial difficulties because of the coronavirus pandemic.
These measures have come in the form of published guidance which sets out the FCA’s expectations of firms across a range of areas, from payment deferrals through to waiving interest, with a nod to ensuring staff within firms are trained and overseen appropriately to implement the guidance.
With six months since the first packages were introduced, it seems timely for firms to assess how successfully they have implemented those relevant to them. It also creates an opportunity to evaluate whether your firm needs to establish additional controls, such as targeted quality assurance. Having previously seen other areas where the FCA have asked firms to complete questionnaires (e.g. CASS 5 compliance), it can also act as a useful preparation tool, in the eventuality questions are ever asked regarding this.
To assist firms in performing these self-assessments, FourthLine has created a downloadable toolkit that carves out relevant areas from the Finalised Temporary Guidance papers and provides a series of questions for considerations. The intended use is that any of the Three Lines of Defence could use this to perform the assessment for the firm.
FourthLine’s toolkit sets out the FCA’s temporary guidance for the following areas:
- Credit cards
- Personal loans
- Motor finance
- High-cost short term credit agreements
- Rent-to-own, buy now-pay later and pawnbroking agreements
- Insurance and premium finance
Should the temporary guidance self-assessment be a useful toolkit for your oversight processes, FourthLine has also created equivalent guidance for the next stage of support for mortgages, consumer credit and overdrafts.
You can download the self-assessment toolkit here>
For further details and for any questions regarding the temporary guidance self-assessment toolkits, please call our experts on 0203 800 1099.
Note: The information contained within the Toolkit is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.