Article
FCA Enforcement Watch 2: The Consumer Duty Moves Into A New Phase Of Scrutiny
The FCA's second Enforcement Watch reveals a shift from initial forbearance to active scrutiny of Consumer Duty compliance, with 11 open investigations now underway. As the regulatory framework matures, firms face increasingly intensive supervisory intervention through VREQs and OIREQs, with fair value assessments emerging as a particular enforcement focus alongside product governance and vulnerable customer treatment.
Herbert Smith Freehills Kramer LLP