The Duty and How Do We Stick To It – Part 2

Mortgage and Savings Customers

In our August newsletter we talked about how FIs can evidence their compliance with The Duty since it came into force in July.

This month we are focussing on how The Duty relates to Mortgage & Savings customers and how you can support them.

To recap on The Duty and how it will affect Mortgage & Savings Customers, FIs must:

  • 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

Among other governance requirements, a firm’s governing body should review and approve the firm’s assessment of whether it is delivering good outcomes for its customers and agree any action required, at least annually.

Do you have trigger systems in place which will alert your Customer Services teams or Relationship Managers to reach out to customers if their behaviour pattern changes? This could indicate a positive or negative change in life circumstances e.g.

  • A large deposit or withdrawal
  • Requests to withdraw money from a fixed-term deposit account before the due date
  • Sudden regular smaller withdrawals

In addition, do you have Signs of Stress wording alerts? These can alert your teams during a telephone or email conversation that a customer is struggling financially, without them actually coming out and saying the words, e.g.

  • They are finding it hard to keep up with living expenses, such as rental or mortgage payments, utility bills and groceries
  • They have missed loan and credit card repayments
  • They are covering unexpected expenses

These are all changes in behaviour which present FIs with the opportunity to evidence compliance with The Duty and offer help, advice and guidance for these customers in what can be a difficult and stressful time.

To read the finalised guidance click here.

If you need help to track and evidence your company’s compliance with The Duty, or put into place any of the services mentioned above, our team can consult and advise on putting the right processes into place which will aid you in the long term.

Contact or 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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