Mills’ recent speech set a clear reminder of this: “We know you may not have every answer. But you need to have a plan for how you will produce one, and how your firm will evidence that it is delivering good outcomes for customers who hold closed products.”

The messaging here is clear: firms need to be able to produce information when required.

The consumer duty is a significant policy from the FCA, and there has been a significant amount of work for firms to carry out. The demand on resources and capacity from firms should not be underestimated, and many firms have taken significant strides in this regard.

While the next phase of implementation may appear to be a more onerous task, particularly given the difficulties with accessing historic system and records, it does provide firms the opportunity to proactively review compliance with the consumer duty and reflect on what has gone well and what has not.

This will give firms a strong framework for preparing for the next phase, and also helps provide them with data and findings that can serve as evidence to the FCA of their commitment to the duty and of their willingness to reflect and improve procedures in line with the rules.

Daniel Seely is a financial services lawyer at national law firm Freeths