Subject matter expert advisory support to accelerate the Firm’s Consumer Duty planning through to formal approval of the Consumer Duty plan

In July 2022 the FCA published new final rules and guidance for a new Consumer Duty that sets higher and clearer standards of consumer protection across financial services and requires firms to put their customers’ needs first.

Our client requested SME support and advice in interpreting the guidance and constructing a plan to assess the impact on their firm and embed any new requirements into a sustainable framework.

We designed and facilitated a series of workshops with the Firm’s senior management to discuss and provide feedback / input on the current draft implementation plan and specifically:

– The scope of the plan in the context of the Firm’s business model, products, services and customers, when considering the Firm’s role in the payment services distribution chains in which it operates;

– How the plan considers work outsourced and/or insourced, including how the Firm engages with other parts of its group as necessary to ensure it meets its specific Consumer Duty obligations;

– The relative prioritisation of activities in terms of the customer risk profile of the Firm’s products and services;

– The completeness of the plan and the extent to which it covers all relevant systems and controls and all products and services, in an appropriate manner;

– How the plan aligns the work required to meet Consumer Duty obligations, with other related activities; and

– How data and other management information is used during the implementation and review phases and how it will be further developed to ensure that the Firm has an ongoing mechanism for measuring customer outcomes and preventing foreseeable harm.