TCC’s (TCC, Recordsure and Momenta) CEO, Joe Norburn was recently featured in IFA Magazine, exploring how the FCA’s Consumer Duty is entering a more mature phase, where the focus has shifted from implementation to evidencing outcomes. As firms move through successive board reporting cycles, the emphasis is now on demonstrating – with clear rationale and judgement – whether customers are genuinely receiving good outcomes in practice, rather than relying on the strength of frameworks alone.
The article highlights how the challenge for boards is becoming increasingly subjective, requiring deeper interrogation of management information and more active oversight of emerging risks. The Consumer Duty is no longer a standalone compliance exercise, but an embedded part of day-to-day decision-making, with firms expected to evidence how they interpret outcomes, intervene where necessary, and ensure that governance drives meaningful improvements for customers.
Norburn stated that: “The next phase of the Consumer Duty isn’t about what firms say they’re doing but about what they can evidence. Boards are being asked to move beyond process and into judgement, where demonstrating good outcomes is far more complex than simply reporting activity.”