The FCA’s long-awaited Consumer Duty came into force on 31^st July 2023, setting higher and clearer standards of consumer protection across financial services and requiring firms to put customers’ needs first.

Mandating a much higher standard of customer care than the previous ‘Treating Customers Fairly’ benchmark, the Consumer Duty expects firms to prioritise achieving good outcomes for their customers across all areas of the business.

These aims are measured according to the Four Outcomes, which cover the most critical areas of regulatory focus: Products and Services, Price and Value, Consumer Understanding, and Consumer Support.

The TCC solutions:

Our subject matter experts are on hand to examine your Consumer Duty approach. Whether you need additional expertise and resource to identify and implement fundamental changes to your business framework, or simply require independent assurance that your approach to embedding Consumer Duty is truly watertight, we can deliver.

By pinpointing where any gaps in compliance may lie and where your attention is most needed, you can make effective enhancements and build a robust, sustainable, ongoing strategy that covers all your bases.

What’s more, we’ve got the tech to help you monitor, review and evidence outcomes.

• Implementation review – Let our regulatory experts review your implementation progress, either by specific risk area or from beginning to end – and highlight any sticking points or inefficiencies that may be keeping your compliance process from running smoothly or from giving you comfort that your controls are within your risk appetite. Our reviews take an analytical lens to key drivers of Consumer Duty success, giving you a personalised report into factors such as:
  • Readiness for transition to Business As Usual (BAU)
  • Culture and risk appetite alignment
  • Ongoing fair value assessment
  • Customer outcomes monitoring
  • Customer communications testing
  • Governance, MI and Board Reporting
  • Approach to closed products
• Ongoing assessments and support – Whether you need an independent validation of your compliance with Consumer Duty or an annual external advisory review of your Consumer Duty annual assessment and corresponding MI, our specialists are on hand to ensure your compliance strategy leaves no stone unturned and delivers the best possible results for customers.
• Evidence compliance the smart way– Under its ‘show me, don’t tell me’ approach, the regulator will expect firms to assess, test, understand and evidence the outcomes their customers are receiving.  A core part of this expectation is that firms should harness the benefits of the data and technology that they have to improve their services. But beyond that, the regulator also expects firms to understand the outcomes they achieve for their customers, as well as have strategy in place to act on their findings.  Let our subject matter experts guide you in developing an effective monitoring strategy that gives you deep oversight of your entire business that can drive actionable insights.

Consumer Duty in summary

Firms are expected to demonstrate compliance with the new Consumer Duty:

• 31st July – for new and existing products or services that are open for sale or renewal
• 31st July 2024 – for closed products or services

In order to ensure consumers are receiving the best possible value for money, firms are expected to continually review and optimise their end-to-end customer journey.

But beyond that, the rules require businesses to put consumers’ interests at the heart of every action and decision that they take throughout the business lifecycle. From product and service design to complaints handling, all now require regular re-examination to ensure they’re fit for the Consumer Duty.

The overarching points of importance for firms are:

• the ability to evidence compliance with the Consumer Duty rules
• increased oversight and governance
• increased Board responsibility

With so many key criteria to evidence and the stakes so high, maintaining compliance is inevitably a significant task for regulated firms, requiring considerable time, resources and budget to consistently get right.

More resources

Want to learn more?

Take a closer look at the FCA’s Consumer Duty initiative with our additional insights:

Consumer Duty explained

• Five need-to-know Consumer Duty principles
• FCA outcome 1: Products and services
• FCA outcome 2: Price and value
• FCA outcome 3: Consumer understanding
• FCA outcome 4: Consumer support
• Consumer Duty and fair value: where are you now?

Practical tips

• How to prepare for the FCA’s new Consumer Duty regulations for positive, compliant outcomes
• A closer look at the FCA’s Consumer Duty expectations
• Why firms need to get serious about Disclosure for Consumer Duty success
• Consumer Duty: what does the FCA expect from SIPP operators?