Consumer Duty
Consumer Duty sets standards of consumer protection across financial services and requires firms to put their customers’ needs first. It materially raises expectations of firms operating in the retail market on how they engage with their customers.
The FCA has brought in a new Consumer Principle (Principle 12), requiring firms to ‘act to deliver good outcomes to retail customers’. Firms also have to consider the value their products provide to customers and act to prevent foreseeable harm.
From 31st July 2023, all firms must have reviewed their products and services in line with the expectations of the Duty. This raises the bar on product management, sales and servicing arrangements and makes management accountable for ensuring the Duty is a part of the firm’s organisational strategy and governance.
Our Approach
Our Services
We work with both first and second lines of defence to embed Duty requirements into their systems and controls and align Duty with the firm’s risk and compliance frameworks.
We offer a range of services to help firms implement and embed Consumer Duty including:
Project Management and Oversight
Helping firms evaluate whether their plans cover all of the Duty requirements and/or manage their implementation of the Duty.
Product review
Reviewing and making recommendations on product governance, distribution and servicing.
Systems and Controls Analysis
Supporting firms to ensure their control environments are effective when implementing and integrating Duty expectations.
Data Evaluation
Making sure firms have appropriate data to measure ‘good outcomes’ and ‘prevent foreseeable harm’.
Integration with Governance
Ensuring end-to-end governance frameworks consider the Duty and senior managers discharge their responsibilities.
Training
Providing training to staff and management on the Duty and the implications.
