Consumer Duty

The FCA introduced the Consumer Duty to raise the standards of care firms provide to their retail consumers. The new requirements affect all aspects of the product and service lifecycle, covering  design, pricing, sales, operations and ongoing customer support. This has required businesses to review and update their existing processes, policies and procedures, while also creating and embedding a range of new ones.

The regulator has said it will be using the Consumer Duty to drive change across retail financial services, with a particular focus on tackling areas of potential concern. Its work on savings accounts, insurance, and ongoing services evidences this new approach in action, with additional data-led supervision targeting high-risk firms for further proactive supervisory attention.

It’s crucial to demonstrate that you’ve implemented and embedded the Consumer Duty effectively, and are monitoring the quality of customer outcomes on an ongoing basis.  Otherwise, there’s an increased risks of losing customers to competitors, complaints, costly redress bills, and regulatory intervention.

How can Bovill Newgate help?

We understand how challenging it can be to keep up with changing regulations and implement them in an effective and proportionate way. This is especially true of the Consumer Duty, where each new FCA publication reveals more about how different elements of the new requirements apply at the coalface.

Our range of Consumer Duty support services focus on helping you align your internal policies, processes, and controls with the latest regulatory expectations, in a way that ensures compliance and operational efficiency.

Consumer Duty reviews

Our Consumer Duty reviews help evaluate the effectiveness of your internal policies, procedures, and controls in meeting key aspects of the Consumer Duty requirements. We offer varying levels of assurance based upon your needs, with a specific focus on product and service design, fair value, customer communications and support, and MI / reporting.

Fair value assessment toolkit

Our fair value assessment toolkit provides a framework to assess your products and services against the Consumer Duty’s price and value requirements. By undertaking a structured evaluation of the charges and benefits of each product and service for your target market, we can help you demonstrate how they deliver value to key customer groups. The evaluation will also help identify any customers where this might not be the case.

If the regulator calls, we can help

We’re also on hand to support you if you are contacted by the FCA in relation to the Consumer Duty. Whatever the reason for the regulator getting in touch, we’ll make sure your response is as effective was possible, reducing the risk of costly, unwarranted regulatory interventions.

Many of our team have significant experience working at the regulator or in dealing with regulatory attention as a consultant or in-house. We also interact with key parts of the FCA on a regular basis: whether that’s helping clients through authorisations, acting as a skilled person, supporting firms who are subject to supervisory attention, or providing feedback on new regulatory initiatives. This means we have a strong understanding of the key areas of regulatory focus and what this means for firms.

Other ways we can support you

Our tailored services include:

• quality assurance of completed product / service and fair value assessments
• processes and templates to help integrate the Consumer Duty into your BAU processes:
  • product / service approvals
  • fair value assessments
  • monitoring plans
  • management information
  • board reporting.
• training for senior leaders and staff on key aspects of the Consumer Duty.

Why Bovill Newgate?

We have significant cross-sectoral experience
We have been helping financial services firms with compliance for over 25 years, with work spanning the wealth management, payments, insurance, consumer credit, retail lending, and asset management sectors.

We’ve worked with a variety of different businesses
We’ve worked with firms of every size – from small fund managers with a handful of staff to multi-national banks – so we’re adept at adjusting our approach to suit the needs and circumstances of each business.

We are experts on the Consumer Duty
We have deep knowledge of the FCA’s product governance requirements and significant practical experience of helping clients integrate this within their businesses. Our team includes former regulators who worked on the design of the Consumer Duty and have undertaken thematic reviews focused on product governance.

We have also helped a range of firms implement and embed the Consumer Duty within their businesses, so can benchmark approaches against a wider peer group.

Get in touch

Get in touch with our experts below for a more detailed discussion about your needs.