The FCA has made clear that the Consumer Duty should be a top priority for Boards. Boards must review and approve an annual assessment of whether the firm is delivering good outcomes for their customers by 31 July 2024.
Firms should be able to demonstrate how their business model, the actions they have taken, and their culture embed the objectives of the Consumer Duty.
The annual assessment should include:
- Results of the firm’s monitoring of customer outcomes;
- Where there is evidence of poor outcomes, an impact evaluation and assessment of root causes;
- Actions taken to address root causes and make redress where appropriate;
- Identification of new and emerging risks and mitigating actions; and
- How the firm’s business strategy is consistent with acting to deliver good outcomes.
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Before signing off the assessment, the Board should agree the action required to address poor outcomes, any identified risks and agree on any necessary changes to the firm’s business strategy. The assessment will be part of the evidence the FCA uses to assess a firm’s compliance with the Consumer Duty. The FCA may ask to see the annual assessment and Board attestation, including the supporting data and related Board minutes. These materials should be sufficiently robust and evidence a developmental mindset – showing how the firm is focussed on customer outcomes, gaps they have identified and necessary actions to improve products and services.
There is no set format to the assessment. Different treatments will be required depending on the complexity of the business, its products and services, its customers and role in the distribution chain. Each firm will be best placed to determine how to present information. Firms will need to consider:
- Who will prepare the report?
- Who will review the report before submission to the Board?
- How will it incorporate input from all three lines of defence?
- How will it meet the needs of the Board in evaluating its approval of the report?
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Before the Board approves the assessment, it should:
- Ensure clear and thorough supporting papers are presented and strong minutes maintained of Board discussion and challenge;
- Identify if there are any gaps in data that need to be addressed or caveated;
- Make sure improved financial performance is not driven by customer behaviours or decisions that are not aligned to the delivery of good outcomes; and
- Identify if any changes are required to the firm’s future business strategy.
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For more information and guidance on preparing the annual assessment, click the link below.
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