Jurisdiction(s):
United Kingdom

FCA Consumer Duty for UK Asset Managers: scope, distribution chains, material influence, exemptions, cross-cutting rules, four outcomes, vulnerable customers, governance and monitoring

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Practice notes

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This Practice Note

This Practice Note explores the implications of the Financial Conduct Authority (FCA)’s Consumer Duty (Duty) for FCA authorised firms holding permissions to: (i) manage an alternative investment fund (AIF); (ii) manage an undertaking for collective investment in transferable securities (UCITS); or (iii) manage investments. It focuses on the key components of the Duty, such as its scope and application (including relevant exclusions, the concept of material influence, and proportional application), the overarching Consumer Duty principle, the cross-cutting rules, and the four outcomes as they pertain to asset management firms. For a summary of the core features of the Consumer Duty with broader application, see Practice Note: The FCA Consumer Duty—essentials. The Duty took effect for new and existing products and services that remained open to sale (or renewal) from 31 July 2023, and for closed book products and services on 31 July 2024. Significant developments are in train. In response to the government’s Financial Services Growth and Competitiveness Strategy, the FCA has set out steps intended to address concerns about the Duty’s effects on wholesale firms and asset managers; see: FCA sets out plans to address impact of the Consumer Duty on...

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Louise Tudor-Edwards

Simmons & Simmons

Louise is a Partner in the Financial Services Regulation group of Simmons & Simmons LLP. Louise specialises in advising buy-side firms, including hedge fund managers, private equity houses and institutional managers, on all aspects of the UK and EU regulatory regimes.Louise’s primary focus is advising fund managers (both in the UK and globally) on regulatory issues including MiFID, AIFMD, SMCR, compliance with the FCA Rules, client documentation, compliance policies and procedures, anti-financial crime requirements and cross-border business. Louise also advises other asset management firms, investment banks, private banks and brokers on a spectrum of financial services law and regulatory issues. Louise is also an expert in environmental, social and governance (ESG) issues and sustainable finance....

Millie Jessel

Simmons & Simmons

Millie is a managing associate in our Financial Services Regulation practice. Millie’s primary focus is advising institutional managers, investment banks, private banks and wealth managers (both in the UK and globally) on a wide range of UK and EU regulatory matters, including advice on MiFID2, UCITS, AIFMD, SMCR, compliance with the FCA rules, compliance policies and procedures and ESG issues. In addition, she has coordinated a significant number of regulatory change projects, including FCA authorisation applications. ...

Jie Clues–Low

Simmons & Simmons

Jie is a supervising associate in the Simmons & Simmons Financial Services Regulatory team in London. Her recent experience includes a focus on advising in relation to the UK Consumer Duty and investor protection rules. Jie also frequently provides advice in relation to the UK licensing perimeter and financial promotion rules, MiFID, UK SMCR and various cross-border regulatory issues. ...

Web page updated on 21/05/2026

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