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Conduct Committee – 12 February 2025

The Conduct Committee reviewed Lloyd’s complaints performance, noting a 19% overturn rate by the FOS, an improvement on Q1 and well below the industry average. Members raised concerns about inconsistent guidance on overseas compensation schemes and the duplication of efforts in implementing the New Zealand Fair Conduct Programme. The committee also discussed FCA consultations, including CP24/2 on enforcement transparency and CP24/28 on operational incident reporting, with the LMA forming a working group to respond.

Further discussion covered the FCA’s regulatory reform letter, with members seeking clarity on implications for wholesale and bespoke markets. The committee agreed to host a joint discussion with the FCA and Lloyd’s on modernising the complaints process. On Consumer Duty, members supported revisiting data collection for vulnerable customers, with a proposal to standardise approaches. Finally, concerns were raised about distributor-owned wordings for UK SME customers, prompting a call for shared experiences and broker engagement.