In a recent Money Marketing opinion piece, Joe Norburn, CEO at TCC Group (TCC, Momenta and Recordsure)  explores how the FCA’s latest guidance on supporting customers through challenging times reinforces a key Consumer Duty principle: firms must proactively identify and prevent foreseeable harm before it becomes visible through complaints, arrears or other traditional indicators. 

 The article argues that changing customer circumstances require firms to continuously assess product suitability, fair value and customer outcomes as market conditions evolve.  

Joe highlights the importance of identifying risks before they become evident through conventional measures, such as complaints or customer arrears. As households continue to face financial pressures, customer behaviours can shift in less visible ways, including delaying financial decisions, reducing cover or disengaging from communications. According to the FCA’s direction of travel, firms should consider these emerging indicators when assessing potential customer harm.  

“A product that offered fair outcomes a year ago may still meet its original design criteria but no longer work in practice for customers with less financial headroom or reduced resilience,” comments Joe Norburn. 

The article also explores the concept of fair value, noting that value can deteriorate even when prices remain unchanged. If customers are no longer able to access benefits, use key features or derive meaningful outcomes from a product, firms should consider whether the value proposition remains appropriate. 

Ultimately, the piece reinforces that the Consumer Duty requires ongoing monitoring, challenge and adaptation. Firms that regularly review customer outcomes and respond to emerging risks will be better placed to demonstrate compliance and deliver good outcomes as regulatory expectations continue to mature.