Consumer Duty reviews

The implementation of the Consumer Duty has resulted in a significant upward shift in the standards of care firms must give to their retail consumers. The new rules impact almost all aspects of how products and services are designed, sold, and operated. This means firms not only have to review and update their existing policies and procedures, but also create, implement, and embed many new ones.

It’s clear already that the FCA will be using the Duty to underpin its supervisory strategy for each sector and drive change in known 'problem' areas. This supervision will also be far more data-led, with data from regulatory returns, open-sources and ad hoc requests used to identify high-risk and outlier firms for further action.

In this context, it’s more important than ever to able to demonstrate that you have implemented and embedded the Duty effectively within your business and are able to monitor the quality of the outcomes your customers are receiving.

How can our Consumer Duty reviews support your business?

Our Consumer Duty reviews are designed to help your business evaluate how effectively you have implemented the Consumer Duty within your internal policies, procedures, and controls. Our range of reviews have been designed to provide differing levels of assurance depending on your needs. But they all have the following things in common:

We focus on the things that really matter
We know the Consumer Duty requirements inside out and have a deep understanding from our work with clients on how the FCA is applying them in different sectors. Our reviews focus on the areas that have the greatest impact: product and service design, fair value, customer communications and support, and MI/reporting.

Our approach is pragmatic and proportionate
We understand how firms work in practice and know that any solution needs to be sustainable commercially, as well as effective from both a compliance and customer perspective.

Our reviews are carried out by teams with significant industry, consulting, and regulatory experience and so we can help you:

• see whether your business is aligned with regulatory expectations
• benchmark how you compare against your peers
• identify any potential gaps in your approach
• take action to mitigate any issues that could leave you open to regulatory action, consumer complaints, and costly redress exercises
• document the steps you have taken to monitor your compliance with the Duty.

How can our Consumer Duty reviews support your business?

We offer five types of Consumer Duty review, depending on the support you need:

• Consumer Duty health check

  Focused on whether your product governance framework includes the policies and procedures needed to meet the Consumer Duty outcome requirements.

  Best for those who want a high-level assessment of whether the firm’s product governance framework contains the policies and procedures needed to meet the Consumer Duty outcome requirements.

  The review provides a gap analysis of your policies and procedures focused on the following areas:

  • product approval
  • fair value
  • customer communications
  • customer support
  • vulnerable customers
  • management information
  • board report.

  We’ll also provide a short-form report highlighting any ‘red flags’ and missing elements.

• Consumer Duty design effectiveness review

  Focused on whether the design of your product governance processes is in line with Consumer Duty requirements.

  Best for those who want a review of whether the design of the firm’s key product governance processes is in line with the Consumer Duty outcome requirements.

  The review covers the design of your:

  • product governance framework
  • fair value assessment framework
  • customer journey framework
  • vulnerable customers policy
  • management information
  • Consumer Duty board report.

  We’ll also benchmark your approach versus comparable firms and provide a report with RAG-rated findings and recommendations.

• Consumer Duty design and operational effectiveness review

  Focused on whether the design and implementation of your product governance processes are in line with Consumer Duty requirements.

  Best for those who want a review of whether the design and implementation of key product governance processes are in line with the Consumer Duty outcome requirements.

  The review covers the design of your:

  • product governance framework
  • fair value assessment framework
  • customer communications policies and procedures
  • consumer support policies and procedures
  • client classification policy
  • vulnerable customers policy
  • management information
  • Consumer Duty board report.

  We’ll assess a targeted sample of completed reviews for specific products/services to examine whether processes are being followed. We’ll also benchmark your approach versus comparable firms and provide a report with RAG-rated findings and recommendations.

• Consumer Duty board report review

  Focused on whether the content and output from your board report and associated board discussion is likely to meet regulatory expectations.

  Best for those who want an assessment of whether the content and outputs from the firm’s Consumer Duty board report are likely to meet regulatory expectations.

  The review covers your:

  • completed Consumer Duty board report
  • management information referenced in the report
  • minutes of the committee where the board report was discussed
  • any actions flowing from the board report.

  We’ll also benchmark your approach versus comparable firms and provide a short-form report with key findings and recommendations.

• Bespoke reviews

  Tailored to your specific needs or focus areas.

  Best for those who want to scope a review to meet specific needs. For example, an outsourced compliance or internal audit review focused on specific aspects of the Consumer Duty.

  The review covers a variety of potential focus areas, including your:

  • product governance framework
  • fair value assessment framework
  • customer communications policies and procedures
  • consumer support policies and procedures
  • client classification policy
  • vulnerable customers policy
  • management information
  • Consumer Duty board report.

   

  We’ll also benchmark your approach versus comparable firms and can tailor the review outputs to reflect your specific needs. For example, by integrating our findings within your internal reporting format.

Other ways we can help you on Consumer Duty

We offer a wide range of additional, tailored services on the Consumer Duty, including:

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

Get started

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