Consumer Duty: When is an extension not an extension?

The countdown is officially underway. Now that the FCA has released the final guidelines for the Consumer Duty, protection providers and distributors alike now have clarity over both what is expected of them and how long they have to meet the regulator's expectations. In theory, at least. Manufacturers of open products (i.e., those for sale as new or renewal) will still have until April next year to complete a review of their existing practices to identify gaps where they fall short of meeting the four outcome rules - so far, so good. However, under the newly-announced rules, th...