FCA information for firms on coronavirus (Covid-19) response

We have significant resources focused on our response, both for the firms we regulate and our colleagues. Dedicated teams have been set up and the situation is being overseen by our executive committee.

Our rules give firms the ability to consider their arrangements and customers’ circumstances. We welcome firms reviewing their current arrangements to address the evolving situation while managing the risks to their employees, customers and the impact on the market.

We are in regular contact with firms to assess their current position, and expect firms to be taking reasonable steps to ensure they are prepared to meet the challenges coronavirus could pose to customers and staff, particularly through their business continuity plans. We expect firms to provide strong support and service to customers during this period. They should be clear and transparent and provide support as consumers and small businesses face challenges at this time. We also expect firms to manage their financial resilience and actively manage their liquidity. Firms should report to us immediately if they believe they will be in difficulty.

We will continue to update this page with information for firms over the coming weeks and would expect to adapt our guidance to firms as the coronavirus situation develops to both facilitate and ensure consumers are protected and markets function well.

• Temporary financial relief for customers: proposed guidance
• Our expectations of payment and retail banking firms
• SM&CR responsibilities
• Regulatory change
• Impact on consumers
• Insurance products
• Mortgages
• Pensions
• Unsecured debt products
• Access to cash
• Mutual societies
• Operational resilience
• Market trading and reporting
• Client assets
• Delayed consultation papers and calls for input

Latest coronavirus news

• FCA expectations regarding funds in light of coronavirus, 6 April 2020
• Senior Managers and Certification Regime (SM&CR) and coronavirus: our expectations of solo-regulated firms, 3 April 2020
• Joint FCA and PRA statement Senior Managers and Certification Regime (SM&CR) and coronavirus: our expectations of dual-regulated firms, 3 April 2020
• We propose temporary financial relief for customers impacted by coronavirus, 2 April 2020
• Dear CEO letter: coronavirus update for firms providing services to retail investors, 31 March 2020
• Work-related travel - responsibilities of Senior Managers, 29 March 2020
• Statement of Policy: Delaying annual company accounts during the coronavirus crisis, 26 March 2020
• Joint statement by the FCA, FRC and PRA, 26 March 2020
• FCA's expectations on financial resilience for FCA solo-regulated firms, 26 March 2020
• Banks and building societies - branch access for essential services, 25 March 2020
• Impact of the coronavirus on firms’ LIBOR transition plans, 25 March 2020
• Bank branch opening, 24 March 2020
• UK markets, 23 March 2020
• Announcement of preliminary accounts: technical Q&A for firms, 22 March 2020
• Key workers in financial services, 20 March 2020

Temporary financial relief for customers: proposed guidance

On 2 April 2020, we proposed a range of targeted temporary measures designed as a stop-gap to quickly support users of certain consumer credit products who are facing a financial impact because of the exceptional circumstances arising from coronavirus:

• Credit cards and coronavirus: consultation on draft guidance and rules for firms
• Overdrafts and coronavirus: consultation on draft guidance for firms
• Personal loans and coronavirus: consultation on draft guidance for firms

Please respond to these consultations before 9am on Monday 6 April 2020 by emailing [email protected] and [email protected].

Our expectations of payment and retail banking firms

The FCA is in regular dialogue with the industry, the government and other regulators to understand the impact of coronavirus on the payments market.

We expect firms to manage the risks to consumers and to provide support to consumers and businesses during these challenging times. We have delayed or postponed work to enable firms to focus on this, and we are actively considering whether we should make further changes to regulatory or supervisory deliverables and expectations.  

For more on the impact on strong customer authentication (SCA), please see the additional section on our SCA webpage for firms. This includes new information on contactless payments, e-commerce and online banking.

On retail banking, please see our statement on access to bank branches.

SM&CR responsibilities

We do not require firms to have a single senior manager responsible for their coronavirus response. Firms should allocate these responsibilities in the way which best enables them to manage the risks they face. There are existing responsibilities specified in the Senior Managers Regime (SMR), for example SMF24 for operational resilience and SMF2 for financial resilience. Firms should have regard to our statement on key workers on 20 March and our recommendation that the SMF1, or most relevant member of the senior management team, be responsible for their approach to key workers.

Regulatory change

We are reviewing our work plans so that we can delay or postpone activity which is not critical to protecting consumers and market integrity in the short-term. This will allow firms to focus on supporting their customers during this difficult period.

One of the immediate actions we are taking is to extend the closing date for responses to our open consultation papers and calls for input until 1 October 2020 and rescheduling most other planned work. See the list below. We have also scaled back our programme of routine business interactions, especially through meetings so that we only contact firms on business-critical requests and responses to the current situation.

We will continue with a small number of regulatory changes which support consumers, particularly the most vulnerable, or where major long-term programmes would be disrupted.

Impact on consumers

Our rules already provide flexibility to firms in a number of areas and we expect them to use this flexibility to support consumers, bearing in mind customers’ individual circumstances.

For example, a number of firms have taken some steps to enable customers’ access to cash, such as waiving fees for individual savings accounts (ISAs) and allowing them to end their term deposits early.

We welcome firms taking initiatives going beyond usual business practices to support their customers. When doing so, firms should notify us so we can consider the impacts and offer support as appropriate.

We still expect firms to deal with complaints promptly. However, where the pandemic prevents this firms should contact us, we understand the pressures firms will be under. Firms are reminded that they should aim to resolve any complaint within 8 weeks (15 days for payments firms). If they cannot, they should write to the customer explaining why they have not met the deadline.

Insurance products

On 19 March 2020, we published an update on expectations for general insurance firms during the pandemic.

Travel insurance

We support firms making consumers aware of the scope of their cover and what exemptions there may be. Consumers should also be able to find this information on firms’ websites in a clear, concise way and have access to call centres. We have provided guidance to consumers on our website.

Health insurance

We also expect firms to make clear any time period restrictions when consumers take out a new policy, for example if a policy will not pay out from 12 or 18 months of taking out a new policy.

Mortgages

Mortgages represent many consumers’ major financial commitment. We have been encouraged by the actions of some lenders in granting flexibility on mortgage payments as a way of protecting consumers. We will be discussing with the industry and updating approaches mortgage providers may take to assisting their customers in the coming days.

On 20 March 2020, we published new guidance for mortgage lenders, mortgage administrators, home purchase providers and home purchase administrators.

Pensions

Communicating certain pension information

We understand that a number of firms are facing challenges implementing our rules that change both the information that firms give consumers entering pension drawdown or taking an income for the first time (including uncrystallised fund pension lump sum) and the annual information given to these customers. These rules come into effect on 06 April 2020 and were finalised in our Policy Statement 19/1 published in January 2019, so we expect firms to have implemented or be in the final phases of implementation.

However, we understand that firms may experience operational challenges in testing and finalising processes, particularly where they are reliant on third parties to complete this work. We appreciate that a short delay in some firms’ implementation of the rules may be unavoidable, though we expect you to implement as soon as reasonably practicable, for the benefit of your customers. If this is later than 31 May 2020, we expect you to notify the FCA under SUP 15 requirements.

Unsecured debt products

Our rules give firms the flexibility to act in the best interests of the customer. We welcome the steps firms have taken to offer support to customers and to encourage them to contact their bank or lender if they are experiencing financial difficulties. 

In the current climate, we want firms to show greater flexibility to customers in persistent credit card debt.

Under our rules, firms are required to take a series of escalating steps to help customers who are making low repayments over a long period. After 36 months of someone being in persistent debt the provider must offer options to help repay the debt more quickly. If customers do not respond within a period set by the firm the card must be suspended.

Given the challenges facing many customers at present we think they should be given more time, until 1 October 2020, to respond to firms’ communications. This means that firms would not be obliged by our rules to suspend the cards of non-responders before then.

This applies both to those who have already received communications from their provider and those that are yet to receive them.

We will be in touch with firms shortly to confirm details of this proposal.

Access to cash

We are working with the Bank of England and the Payment Systems Regulator to understand problems consumers may have accessing cash, and ensure the UK learns the lessons from other countries’ experience of coronavirus.

UK firms have taken steps to help ensure consumers have access to cash, including the raising of cash machine withdrawal limits.

We are confident electronic payment providers have capacity to cope with the potential changes in transaction numbers.  

We recognise that a growing number of people may use online or phone banking services, in some cases for the first time. Firms should continue to help vulnerable consumers access their banking services – online or over the phone. Firms should also remind consumers to be aware of fraud and protect their personal data.

Mutual societies

We’ve provided an update for mutual societies on applications and annual returns.

Operational resilience

We expect all firms to have contingency plans to deal with major events and that the plans have been tested. Alongside the Bank we are actively reviewing the contingency plans of a wide range of firms. This includes firms’ assessments of operational risks, the ability of firms to continue to operate effectively and the steps firms are taking to serve and support their customers.

Firms should take all reasonable steps to meet the regulatory obligations which are in place to protect their consumers and maintain market integrity. For example, if a firm has to close a call centre – requiring staff to work from other locations (including their homes) – the firm should establish appropriate systems and controls to ensure it maintains appropriate records, including call recordings if required.

We will continue proactively discussing with firms and trade associations the issues they are facing, and we will be continuing our active dialogue with them in the coming days and weeks.

Our consultation paper sets out further information on operational resilience matters that firms should be considering.

Market trading and reporting

As firms are moving to alternative sites and working from home arrangements, they must consider the broader control environment in these new circumstances.

Firms should continue to record calls, but we accept that some scenarios may emerge where this is not possible. Firms should make us aware if they are unable to meet these requirements. We expect firms to consider what steps they could take to mitigate outstanding risks if they are unable to comply with their obligations to record voice communications. This could include enhanced monitoring, or retrospective review once the situation has been resolved.

Firms may experience difficulties in submitting their regulatory data, in which case we expect them to maintain appropriate records during this period and submit the data as soon as possible. Firms should not unnecessarily delay these submissions. If firms have concerns, they should contact us as soon as possible.

Firms should continue to take all steps to prevent market abuse risks. This could include enhanced monitoring, or retrospective reviews. We will continue to monitor for market abuse and, if necessary, take action.

We note the recent statement from the European Securities & Markets Authority (ESMA) regarding upcoming changes to the tick size regime for certain firms, required by the EU Investment Firms Regulation. We support the statement. We will also not prioritise supervision of the new requirements at this time. We expect firms to focus on minimising the potential for operational disruption. We will keep this situation, and our position, under review.

Client assets

We have received queries on client assets (CASS) compliance related to the current disruption caused by coronavirus (Covid-19). We summarise some of the queries received and our position on the relevant issue.

Delayed consultation papers and calls for input

We have decided to extend the closure dates for the following published consultation papers and calls for input until 1 October 2020.

Delays to publications and other activity

We have decided to delay the following publications due before end June. We will provide updates at an appropriate point.