Three key questions for Consumer Duty – ‘So what?’ ‘why?’ and ‘how?’

Firms should now be thinking about their Board report at the end of the first full year of the FCA’s Consumer Duty rules.

Much has been done since we first saw the rules – customer journeys reviewed end to end to improve customer outcomes, communications reviewed and improved to increase understanding, price and value assessments carried out, management information scrutinised, policies and procedures updated, the list goes on.

But – so what?  What your Board (and the FCA) will be interested in is what has changed as a result of all this work.  What changes have you made to your products?  What have you learnt from your price and value work? Can you demonstrate that customers are getting better outcomes as a result of what you have done/changed? How do you know that?  Make sure you are capturing and documenting the positive changes you are making.

I think the most powerful application of ‘so what?’ is on management information (MI).  Firms are still wrestling with what is the best MI to support Consumer Duty.  We’ve all seen swathes of MI that is collected on every aspect of a firm’s business.  However, if it’s not answering a ‘so what?’ question from a Consumer Duty perspective, how does it help senior management or the Board be confident that Consumer Duty is being delivered effectively and embedded in the business?

As for ‘why?’ and ‘how?’, when a customer complains about something it’s important not only to ensure the customer position is rectified but also to understand ‘why’ it happened and ‘how’ things can be changed so it doesn’t happen again.  The same applies to risk incidents – ‘why’ did it happen and ‘how’ can you stop it happening again?.  There’s nothing particularly new in this; root cause analysis has been around for many years, but I think Consumer Duty gives it a new purpose, which is ultimately continuously improving customer outcomes.  Better customer outcomes make business sense too and improve employee satisfaction.

I couldn’t write a blog about Consumer Duty without saying this is not a once and done exercise.  But hopefully these simple questions will help you continue to challenge yourselves as the journey continues.

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