Consumer Duty Board Report template
As you will all now be aware, the Consumer Duty (‘the Duty’) sets the standard of care that firms should give to customers in retail financial markets. As part of the FCA’s expectations, the Duty requires firms to deliver good outcomes which are reflected in their strategies, governance, leadership and people policies, including incentives at all levels.
As a member of your firm’s Board or equivalent governing body, it is important to note that you not only hold the torch for ensuring that the Duty is properly embedded within your firm, but also, that you are personally accountable for the consistent delivery of good outcomes to your customers.
With the above in mind and the first iteration of your firm’s annual Consumer Duty Board report looming, we have provided a few things to think about when carrying out your obligation to provide meaningful and effective challenge to your report:
How has your firm’s purpose evolved to ensure good customer outcomes are at the heart of everything your firm does?
How can your firm demonstrate that it has not only implemented the Duty’s requirements, but also that its spirit has been embedded and is understood at all levels of your firm?
How does the report reflect that your staff are empowered and feel safe to challenge and raise issues where they feel the firm might not be acting to deliver good outcomes for customers?
How has your firm defined what good outcomes look like (over the short, medium and long term) for customers using your products/services?
How does the report show that your firm really know its customers and has it used this information to place them into meaningful groups?
Does your firm understand the factors that may impact the outcomes each group of customers may receive?
Are any of these groups experiencing different outcomes and what is driving this?
Is your MI insightful, meaningful and does it allow you to provide effective challenge (or is it merely a case that it tells a ‘good story’ and that everything is ‘working well’)?
What are the gaps, how will these be improved and who is responsible for their delivery?
How does the report clearly show responsibility for addressing these gaps, risks or issues, detail any actions taken, and explain how quickly your firm is acting to improve customer outcomes?
As noted in Nisha Arora’s (FCA Director of Cross Cutting Policy and Strategy) recent speech: the Consumer Duty is not a matter of once and done.
When reviewing and providing challenge your firm’s annual Consumer Duty Board report. It is important to keep in mind that the Duty requires your firm to adopt a culture continual learning and improvement. As this will not only ensure that your firm focuses on good customer outcomes, but also will help your firm act quickly to put things right should things go wrong. Keep any eye out for our next Consumer Duty Board report blog where we will talk about this in more detail.
Consumer Duty Board report template
As it is the first one, we know that writing your annual Consumer Duty Board report can be daunting.
Aside from it being a specific requirement, it is also a key component which allows your firm to demonstrate how it has implemented the Consumer Duty and the outcomes your clients receive. Moreover, it is also a tool that enables your firm to illustrate how it continues to learn and improve your customer outcomes. This is especially important, as the Consumer Duty remains a top priority for the FCA.
Our template ensures you can easily create a comprehensive, compliant and informative Consumer Duty Board Report. This will give you confidence in what you’re writing and allow you to focus your precious time on substance rather than structure.
Please get in touch if you would like a copy of our Consumer Duty Board Report template. contact@avyse.co.uk
