Consumer Duty – Post Implementation Governance

Six months on from the implementation of Consumer Duty, firms are transitioning from a project implementation governance to operational oversight.

2024 is the first year that firms are recording, collating and reporting on consumer outcomes and there are mounting expectations on data quality and effective decision-making.

How are good consumer outcomes embedded in your governance?

Committees or Forums?

The decision to set a dedicated Consumer Duty Committee / Forum or to embed the responsibilities within an existing Committee is largely aligned to the existing governance structure. The FCA has not prescribed the creation additional oversight bodies to support Consumer Duty outcomes. More important is the clarity and effectiveness of governance setups, including:

• Clarity of roles, responsibilities, and communications
• Effective delegated decision making / escalation channels
• Engagement of the Consumer Duty Champion
• Data and management information is focused on Consumer Outcomes
• Timely interactions with Pricing and Product governance bodies
• Timely and regular meetings demonstrating effective challenge and actions

Data Evolution

In implementing the Consumer Duty many firms identified that existing performance metrics focused on internal or commercial measures. To monitor and assess Consumer Outcomes a new suite of management information (MI) and performance metrics is required.

Firms who identified gaps in their performance metrics were well placed to develop and refine this new data and embed this within their operations, monitoring and oversight. With nearly six-months of data, early 2024 is a great time to review the collection, collation, reporting and use of this data to ensure that it’s being collected consistently, correctly and accurately, and that outcomes are effective and proportionate.

How can we help?

We have experience of working with firms throughout their Consumer Duty implementation projects and provide independent assurance that effective controls are in place to meet the FCA requirements.