Global Trustee and Fiduciary Services Bite-Sized Issue 1 2025

21 QUICK LINKS AIFMD CRYPTOASSETS EMIR FINTECH MIFID II/MIFIR MMF NBFI OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG ASIA IRELAND LUXEMBOURG NETHERLANDS NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 1 | 2025 • Taking action based in these insights: – It was not always clear whether there had been appropriate discussion on the data at decision-making forums and what actions would be taken. This means opportunities to make changes to improve consumer outcomes are being missed. • Assessing and measuring the impact of these actions: – Firms did not always measure the impact of interventions they had made to ensure these were the right changes to make. This means that sometimes firms pursued actions even though they were not as effective as they might need to be. Link to the Report here Consumer Duty Board Reports: Good Practice and Areas for Improvement On 11 December 2024, the FCA published its findings of its review into firms’ approaches to completing the first annual Consumer Duty Board report. The report sets out the results of a targeted and thematic review that the FCA carried out on the first annual Consumer Duty board reports from 180 firms. The report highlights five key aspects of good reports: • Clear outcomes focus: – Dedicated sections focussed on each of the 4 outcomes, detailing what good outcomes looked like for customers holding their products. • Good quality data: – Commentary on good outcomes supported by good quality Management Information (MI) that backed up the firm’s conclusions. • Analysis of different customer types: – Consideration of different groups of customers, including those with characteristics of vulnerability. • Clear processes for production of the report: – Processes in place for producing reports for firms’ governing bodies to review and approve within the necessary timeframe. • A focus on culture throughout the firm: – Commentary emphasising firms’ commitment to effectively implementing the Duty and the role of a positive culture in delivering good outcomes. The report also highlights five areas for improvement: • Better data quality: – Some firms did not have sufficient data quality to justify conclusions or to give governing bodies adequate assurance that firms are meeting their obligations under the Duty. Some also did not accompany their MI with adequate explanations to clearly illustrate it constitutes evidence of good outcomes for customers. • Comprehensive view across distribution chains: – Some reports did not contain evidence that an appropriate amount and types of information have been shared between the firm and third parties across the distribution chain. • Analysis of different customer types: – Some firms did not evidence that adequate consideration had been given to outcomes for different groups of customers, including those with characteristics of vulnerability.