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If you are fortunate enough to be your firm’s Consumer Duty champion, you are no doubt thinking hard about what your firm is doing to implement the Consumer Duty.
We hear from our clients about the plans they are making, the rule mapping they are undertaking and the gap analyses that are being completed. We also see progress – some firms are already changing their processes (or implementing new ones.) while others are still formulating their plans. The Financial Conduct Authority (FCA) in its brief update on 5 October (Consumer Duty - information for firms), has clarified what stage those plans need to be at by the end of October.
A clear final destination guides the firm
What we see less of from those we talk to is clarity about what success looks like for the firm. To put it another way, what the final destination of their plans is. Clearly the plans are essential as are the actions that deliver them. However, firms will be more likely to deliver the change the FCA envisages if they have a clear sense of what success looks like – their Consumer Duty destination.
Your destination may not be exactly the same as your peers
Each firm has to find their own destination – in line with the regulation of course. One option might be a strategic view on where the overall programme will take you – what will “look and feel” different for your customers and for your firm once you have delivered the change. Another way could be a more granular view on what success looks like for each of the four outcomes.
Your board will value a clear objective
This clarity of destination will be beneficial in helping you and your board to understand what the business is trying to achieve. So, when the board comes to sign off the delivery of plans in nine months’ time, it isn’t just saying that a bunch of disparate actions has been completed, but rather that a destination has been reached, a real change has been implemented. The board can then explain what is different in real terms, when it states that the Consumer Duty is being embedded and the business is focusing on customer outcomes.
So, when your firm develops its plans for the end-October deadline, make sure it doesn’t lose sight of its final destination.
24.10.22
Christopher Atkinson, Managing Director, Promontory Financial Group, a business unit of IBM Consulting
03.04.23
16.01.23
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