The opinions expressed here are those of the authors. They do not necessarily reflect the views or positions of UK Finance or its members.

Firstly, moving to full compliance with the duty for open products. Secondly, they’re implementing the changes in time for the July deadline for closed products. 

However, a key challenge that should not be underestimated or delayed is looking at designing developing and populating the annual board report to provide reassurance that the banks is fundamentally delivering good customer outcomes.

One key component of those considerations (arguably heightened for banks) is achieving the right balance in terms of the depth of information presented in the board report. Given the size and complexity of most banks, this balance will be critical. Too little information will create challenges in giving boards the required level of reassurance about the good outcomes that the bank is delivering.  

Conversely, however, too much information will risk the board being unable to really draw out where the key areas of reassurance and - by the same token, areas of further development and enhancement that exist within the bank’s approach to embedding consumer duty. Consequently, banks are understandably wrestling with how to get this balance ‘just right’.

As such, we are seeing a number of banks start to test and dry run their report to gauge, at an early, stage, the Board’s appetite for depth of the reporting – or, as minimum, the optimal approach to layering the information. The ultimate aim is to make the report as accessible, engaging and holistic but fulsome where required – and therefore as effective and impactful as possible.

We explore this balance as well as the how best to approach the report, critical design principles, key content for the report and the overarching governance and oversight the report needs, in our article here.

However, do not hesitate to get in touch if you’d like to discuss directly. This topic is taking up an increasing prominence with boards (and specifically board champions) and this will only grow as the July deadline looms large in 2024.