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Dear CEO/Director | Release Date: 6th April 2023

To read a shorter summary of this Dear CEO/Director letter, click here.

To access the original FCA document, click here.

Long Summary

This letter from the Financial Conduct Authority (FCA) addresses CEOs and directors of firms involved in providing Contracts for Difference (CFD), spread bets, or rolling spot foreign exchange to retail consumers. It outlines the expectations and timeline for implementing the Consumer Duty, emphasising the need for a more outcomes-focused approach to consumer protection.

Timeline for Implementing the Consumer Duty

The FCA has provided a specific timeline for firms within the CFD portfolio to prepare for and implement the Consumer Duty:

Application of the Consumer Duty to CFD Firms

The Consumer Duty applies to all firms that can determine or influence customer outcomes. This includes firms without direct retail customer relationships but who play a role in the product or service lifecycle that reaches retail customers. The Duty expects firms to act in good faith, avoid causing foreseeable harm, and enable consumers to pursue their financial objectives effectively.

Requirements and Expectations

The FCA’s Finalised Guidance from July provides comprehensive details on the requirements of the Consumer Duty, including:

Embedding the Consumer Duty

To successfully embed the Consumer Duty, CFD firms must:

Feedback on Implementation Plans

Feedback from the FCA’s review of firms’ implementation plans indicates that while many have embraced the new Duty, some are lagging. Firms must:

Supervisory Approach and Next Steps

The FCA is prioritising the Duty in its regulatory strategy and will actively supervise firms for compliance. It will take action against firms that do not prepare adequately by the implementation deadlines or fail to meet the Duty’s standards post-implementation.


Firms must treat the implementation of the Consumer Duty as a priority, ensuring it is deeply embedded in their culture and operational practices. The FCA expects firms to proactively address any deficiencies and align their strategies to deliver positive outcomes for consumers. This involves a shift towards more rigorous standards of consumer protection and a commitment to fair and transparent treatment of customers across the financial services sector.

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