Michael Oxlade

Simmons & Simmons

Michael Oxlade is a member of Simmons & Simmons’ financial services regulatory practice in London, focusing on regulated payments and lending. Michael works with major banks, FinTechs, and payments firms on the regulation of payment services and consumer credit lending. Before joining Simmons & Simmons in 2024, Michael spent more than a decade in the consumer finance team at another London-headquartered global law firm.

Practice Area

Financial Services

Panel

Contributing Author

Qualified Year

2015

Experience

Simmons & Simmons LLP (2024 - 2025)
Hogan Lovells International LLP (2013 - 2024)

Qualifications

GDL, 2011
Bachelor of Arts, 2009

Education

University of Oxford (Somerville College), 2009

2 Contributions by Michael Oxlade

PRACTICE NOTES

FCA Consumer Duty in UK retail banks and building societies: scope and supervisory priorities on savings fair value, SMEs, customer support and branch closures, mortgages, vulnerable customers, and data/AI

Note The FCA issued its Regulatory Priorities Report for retail banking in March 2026 (see FCA publishes 2026 regulatory priorities report for retail banking). This Practice Note will be updated to take account of the Report. This Practice Note examines how the FCA’s Consumer Duty applies to retail banks and building societies. For simplicity, the term ‘retail bank’ is used throughout to cover both institutions, unless a distinction is required. The Consumer Duty became effective on 31 July 2023 for new and existing products and services that remain open for sale or renewal. In broad terms, the Duty applies to firms carrying out regulated activities in the UK within the FCA’s remit. Given their extensive product and service ranges, retail banks may have direct relationships with retail customers, and indirect ones through participation in distribution chains that end with a retail customer. The Consumer Duty is relevant in both scenarios; however, the extent of its application depends on the firm’s responsibility for setting, or materially influencing, outcomes for retail customers. This Practice Note considers the application of the Consumer Duty to...

Financial Services

CHECKLISTS

FCA Consumer Duty Fair Value: Checklist for PRIN 2A.4 Assessments Covering Manufacturers, Distributors, Target Markets, Pricing, Vulnerable Customers, Closed Products and Governance

This checklist helps practitioners grasp and consistently apply the FCA’s Consumer Duty requirements for evidencing fair value effectively. It should be considered alongside other relevant practical Consumer Duty materials and references: for information on the main elements of the Consumer Duty with general application, see Practice Note: The FCA Consumer Duty—essentials; also for a suite of sectoral guidance and checklists see: Consumer protection and FCA Consumer Duty—overview for key developments relating to the FCA’s Consumer Duty, see: The FCA Consumer Duty—timeline Background Under the Consumer Duty, four outcomes cover the central and key aspects of the firm–customer relationship. The second outcome is the Price and Value Outcome, which is concerned with an overarching obligation that products must deliver ‘fair value’ to customers. Under PRIN 2A.4: value is the relationship between the amount paid by a retail customer for the product and the benefits they can reasonably expect to receive from the product; and a product provides fair value where the amount paid for the product is reasonable relative to the benefits of the product Under the Price and Value Outcome, obligations apply to both a manufacturer as well as a distributor equally...