The Duty and How Do We Stick To It – Part 1

The date we have all been working towards has come and gone, without fanfare and fireworks. The Consumer Duty has now come into force and the hard work you and your teams have done is over.

Or is it? Now The Duty is the standard all FIs are working under, you will need to continue to maintain it – and if need be, show evidence of how you are complying.


Which can be evidenced in the following areas –

  1. What action have you taken as a result of your fair value assessments, and how are you ensuring this action is effective in improving consumer outcomes?
  2. What data, MI and other intelligence are you using to monitor the fair value of your products and services on an ongoing basis?
  3. How are you testing the effectiveness of your communications? How are you acting on these results?
  4. How do you adapt your communications to meet the needs of customers with characteristics of vulnerability, and how do you know these adaptions are effective?
  5. How have you satisfied yourself that the quality and availability of any post-sale support you have is as good as your pre-sale support?
  6. Do individuals throughout your firm – including those in control and support functions – understand their role and responsibility in delivering the Duty?
  7. Have you identified the key risks to your ability to deliver good outcomes to customers and put appropriate mitigants in place?
The Duty outlines how you can monitor the outcomes

Firms have to be able to identify poor outcomes and take appropriate action to rectify the causes of the poor outcomes. They must also continuously learn from their focus and awareness of the outcomes that their customers experience in practice.

Firms can expect at every stage of the regulatory lifecycle to be asked to demonstrate how their business models, the actions they have taken, and their culture are focused on good customer outcomes.

Our rules therefore require firms to:

• monitor and regularly review the outcomes their customers are experiencing to ensure that the products and services that firms provide are delivering outcomes consistent with the Duty

• identify where customers or groups of customers are not getting good outcomes and understand why

• have processes in place to adapt and change products and services, or policies and practices, to address any risks or issues identified and stop it occurring again in the future.

A firm’s governing body should review and approve the firm’s assessment of whether it is delivering good outcomes for its customers which are consistent with the Duty and agree any action required, at least annually.


To read the finalised guidance, just click the image above.

If you need help to track and evidence your company’s compliance with The Duty, our team can consult and advise on putting the right processes into place which will aid you in the long term. Contact call 07799 113535.
0207 084 6387
07799 113535
University of Sussex Innovation Centre
No.1 Croydon, 11th Floor
12-16 Addiscombe Road
Croydon CR0 0XT

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