The FCA Consumer Duty represents the biggest overhaul of UK regulation since the Retail Distribution Review
Jonathan Warren
The FCA's new Consumer Duty: how do you measure up?
Written by Jonathan Warren on
The Consumer Duty is seeking to set a higher standard for retail financial services, with the focus on delivering good outcomes for consumers. In shifting to outcomes-focused regulation, it represents arguably the biggest overhaul of UK regulation since the Retail Distribution Review.


Steve Jobs argued that you start with the customer experience and the value you can add to consumers and work back to the proposition and technology. An idealised view of the world and very reflective of the spirit of the incoming regulation, but financial services does not reinvent its products and services from a blank piece of paper and with the same frequency as consumer electronics.


The challenge for firms and the senior leaders responsible for Consumer Duty is not insignificant, but it represents a great opportunity to reset consumer trust in financial services. Consumer Duty shifts focus from commercial endeavour to consumer outcomes, but organisations that treat Consumer Duty as an opportunity will be well placed to achieve commercial success by delivering great outcomes.


If we view the Consumer Duty at capability level using the Altus reference model, Consumer Duty impacts across the organisation from propositions management, including assessment of value, through to distribution and target market, communications and managing the customer experience. Firms also need to implement robust reporting and governance structures to monitor, assess and evidence compliance, with appropriate board level engagement and oversight. Beyond the tangible changes required, the Consumer Duty brings a change in mindset and culture that firms must embed across the organisation, from the top down.


Consumer Duty Capability Model


The regulator may state higher levels of consumer protection in retail financial markets, but intermediary focused businesses within the value chain should be under no illusion that the Consumer Duty does not apply to them. Advisers are at the sharp end, judging what good value and service looks like and seeing outcomes up close.  Product manufacturers will depend on their feedback from customers more than ever.


How do you solve a complex problem like Consumer Duty?

Altus is built on comprehensive industry models, expertise and repeatable methodology and in keeping with that approach, we have developed the Consumer Duty Review. The Consumer Duty Review is a comprehensive and repeatable framework for undertaking a detailed review of a firm’s performance under the four outcomes.

Consumer Duty Wheel

Key features and benefits of the Consumer Duty Review:

  • The board and senior leaders get an understanding of the ‘as is’ position through detailed interrogation of 20+ areas, under the four outcomes and in reporting and governance structures
  • A RAG rated, visual dashboard reflecting the review findings
  • Recommendations based on the difference between the status quo and the expectation described in the regulator’s guidance
  • A benchmark of your review outcome against the average and range we have seen across the industry


Altus Consumer Duty Review

For more about the Consumer Duty and how Altus can help you comply, please contact Jonathan Warren or Jon Dean.

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