The FCA has written a Dear CEO letter to provider bosses to alert them to potential gaps in data as the Consumer Duty deadline for closed products looms.

The Consumer Duty requirements, implemented last July, will be extended to closed products and services from 31 July.

The FCA will expect firms to apply most of the Consumer Duty rules to closed products and services to ensure fair treatment of customers.

In a letter to CEOs this week, Sheldon Mills, FCA executive director of consumers & competition, urges CEOs to make 5 key areas a priority to ensure firms meet the new guidelines.

He says firms must identify areas such as gaps in data and fix any issues before the Duty is extended.

He has written to CEOs heading a variety of firms including those providing investments, asset management, life insurance and retail banking.

Mr Mills says with less than three months to go there are five key priorities firms should look at. These are:

• Gaps in firms’ customer data
• Fair value
• Treatment of consumers with characteristics of vulnerability
• Gone-away or disengaged customers
• Vested contractual rights

He said: “While these issues are not unique to closed products and services, they are likely to be more widespread or acute.

“This list is not exhaustive, but draws on our supervisory insights, together with feedback given to us through our engagement with firms, trade bodies and other stakeholders.”

Mr Mills said that the FCA understood that data gaps, vulnerability and fair value were likely to be the “most challenging themes” for Consumer Investment firms.

He thanked firms that are on track to comply with the Duty for closed products by 31 July.

He clarified that the Duty applies in full to closed products and services from the deadline but does not apply to the past actions of firms. Instead, it applies to the ongoing actions of firms from 31 July 2024. For example, communications issued by firms from 31 July 2024 for a closed product or service will need to comply with the Duty’s higher standards.

• See FCA Finalised Guidance and Consumer Duty homepage.