FCA has set out its expectations on how firms should deal with post and paper-based processes during the pandemic.
It says it recognises firms will be finding it hard to process post and comply with paper-based processing requirements in a timely manner, but that they should be notifying FCA if they are unable to comply fully with its relevant rules.
In particular, firms should try to ensure that all customers are not disadvantaged because of delays and should make particular efforts to contact customers who do not use online services – who are most likely to be vulnerable customers. FCA expects firms to be able to show what they have done to mitigate the impact of non-compliance. They should, for instance, collect post as often as thy can, and make sure they return client funds promptly if it is not possible to proceed with a transaction. They should give updates on public channels as to how they will treat post and incoming cheques, update customers on market conditions and explain how customers can check their statements (and warn that they may be late). Firms should be asking customers who have sent instructions and cheques that have not been processed to contact them urgently, and consider how to comply with CASS in respect of unbanked cheques.
Firms should still be carrying out suitability assessments, finding alternative methods to face-to-face meetings.