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

During June 2024 the UK Finance Chief Compliance Officer discussion group shared thoughts and individual approaches during a virtual and in person session.

These sessions were facilitated by Stuart O’Sullivan of Protiviti, a global business consulting firm and an associate member of UK Finance.

As part of the discussions Protiviti shared a good practice approach to Outcomes Monitoring. The key elements of this are:

1. Start with the end-to-end customer journey or product lifecycle and identify the key customer touch and decision points and the regulatory requirements along this
2. For each key touch and decision point and regulatory requirement define what you want the intended good outcome to be and the contra poor outcome or risk to good outcome that the customer journey should prevent
3. These defined good outcomes can then be broken into constituent parts or elements that can be tested and measured as part of a monitoring and testing framework
4. The monitoring and testing will result in quality assurance, data collection, reporting and assurance for governance and oversight functions
5. All of which should lead to relevant analysis and assessment, including – and this is really key – root cause analysis to deliver ongoing improvement activity.

In practical terms and taking a customer complaints journey as an example, an intended outcome for a customer complaint could be something like “a customer receives appropriate redress where they have experienced harm”. This is the outcome we want our assessment of a complaint to have resulted in.

To assess whether this outcome has been delivered we would need to review the quality of complaint handling to look at whether the customer experienced actual or potential harm at all customer touch points, decisions points, interactions and regulatory requirements of the product or service being complained about. This individual outcome assessment would feed into a broader collection of complaints outcome testing which would be reported into appropriate governance.

Outcomes Monitoring and Testing is a critical part of the overall Outcomes Monitoring Framework. The Framework will include all your data about customer usage, price and value, customer understanding, customer support and feed into your holistic assessment as to the outcomes your products and services are delivering for customers.

At the recent FCA event marking the anniversary of the first year of Consumer Duty the regulator confirmed that Customer Outcomes Monitoring would continue to be a focus area for it in its monitoring and supervision of the embedding of the Duty. While many firms have begun to make some progress on developing outcomes monitoring frameworks, embedding these and driving continuous improvement through the outcomes monitoring framework and the root cause activity is the next and ongoing challenge.

Upgrade your weekends with the Protiviti LinkedIn Weekend Digest newsletter, delivered straight to your inbox.