By Ciara Davies.
In its statement on 13 May, the FCA asks firms to continue to comply with the requirements for post and paper-based processes, but recognises that in the current circumstances, this may not be fully possible.
Firms need to notify the FCA as soon as possible if they believe that they will be unable to comply. The FCA asks firms to ensure that customers are not disadvantaged because of delays and to make a particular effort to contact customers who do not access services online, with a particular emphasis on supporting vulnerable customers.
Firms must also mitigate the impact of any non-compliance with postal and paper processes and demonstrate the steps taken to do this to the FCA. The aim is to return to full compliance as soon as possible.
Firms also need to provide general updates on how they will treat post and cheques through their website and other channels, such as social media. In addition, customers who have sent instructions or cheques that have not been processed should be asked to contact the firm urgently by telephone or electronic means. Where possible, customers should receive the services or cover they require. For example, this could include retrospective cover. Although, the FCA warns that where uncashed cheques are client money under the CASS regime, the firm must consider whether proceeding in this way might breach CASS rules and expose its other clients to a risk of client money shortfall.