The UK Consumer Duty: Next Steps For Private Fund Managers

In our previous Client Alert, Back to Work: The FCA's 2022-23 Priorities for Private Fund Managers, we mentioned the need for managers to consider the new consumer duty rules contained in PS22/9: A new Consumer Duty.

The first consumer duty deadline is the 31st October 2022, the date by which the U.K. Financial Conduct Authority (FCA) expects firms' boards (or equivalent management body) to have agreed implementation plans "to meet the duty standards".

For most private fund managers, who do not target or do not plan to target retail investors, the consumer duty should not give rise to regulatory obligations. Managers will, however, need to determine whether this is the case and, if the duty does apply or may apply in future, what they need to do to meet the duty standards.