Consumer Duty July 2023 update

So what have we done regarding the 4 outcomes?

Product and Services – Offering UK regulated funds, the IFSL Marlborough Funds have been subject to increasing regulation for many years now and benefit from complying with existing PROD rules which the FCA has confirmed are in line with the Duty. Marlborough has, though, been reviewing existing frameworks and strengthening controls to ensure compliance with the Duty where there are additional requirements.

Price and Value – Again, being UK funds, all our fund products have had to comply with the COLL value assessment rules for several years now, and this requirement has been fulfilled by our group ACD, IFSL. Given the requirements of Consumer Duty, it is important to communicate more widely the outcome of these assessments through the EMT 4.1. There was a key milestone for doing this by the end of April 2023 and we are pleased we were able to clearly meet this deadline. In summary we can confirm that all our IFSL Marlborough Funds were deemed to be providing value for money.  

Useful links:
Marlborough Assement of Value Report
EMT

Consumer Understanding – Over a number of years the fund industry has been simplifying how it communicates with consumers, and here at Marlborough we have been ensuring that we comply with Asset Management Market Study guidance and ‘fair, clear and not misleading’ requirements, as well as general industry guidance on how to communicate clearly.

As part of Consumer Duty we have taken this further and used the opportunity to revisit our investor-facing documents and began testing our factsheets, as well as ranking the impact of other documents so we can develop a clear testing programme with consumers.

We have also embarked on a website review and are looking to make numerous improvements to this key information source to enhance the investor journey.

Consumer Support – At Marlborough we have limited direct investor contact, but appreciate that we are a key part of the support function that other firms might call on to support investors.

If you believe we can do anything to help your business support your investors we would welcome the opportunity to discuss this further.

Don’t forget……

Consumer Duty doesn’t end on the 31^st July - this is just the beginning. We expect lots of communication with firms post-July as well as further participation in industry discussion groups to learn and enhance the ways in which the industry is living and breathing the Duty in a live environment.

Firms also need to consider that by July 2024 they must have completed their first annual board report addressing compliance with the Duty. Also by this date all firms must have addressed their closed products which, under the rules, were given an extra year to comply.

Conclusion

We continue to work through our implementation plan.

We are keen to engage with distributors, so please contact us if you have any questions or would like to discuss any Consumer Duty-related topics.

A key element for us now is to continue to conduct our consumer testing and work with external partners on information-sharing regarding the use of our products.

We aim to provide the marketplace with great products which give advisors, asset managers and investors great investment solutions, and look forward to using the principles of Consumer Duty to allow us to continue to do this.

Capital is at risk. The value and income from investments can go down as well as up and are not guaranteed. An investor may get back significantly less than they invest. Past performance is not a reliable indicator of current or future performance and should not be the sole factor considered when selecting funds.