Consumer Duty: Board implementation plans

With less than a week to go until the first Consumer Duty milestone, firms and in particular Boards, must now focus on agreeing an implementation plan by 31 October 2022.

While firms are not yet expected to have fully scoped all required work, Boards will be expected to have agreed on their implementation plans to ensure timely compliance and understood what they need to do to oversee the firm's ongoing compliance.

We have highlighted six key areas below that Boards should consider within their own firm’s plans:

1. Scope

  • Identify and prioritise key workstreams
  • Undertake a gap analysis of the Duty
  • Agree roles and responsibilities in the distribution chain

2. Governance and Oversight

  • Identify a Board Champion for oversight and challenge
  • Implement robust programme governance
  • Consider “reasonable steps” under SM&CR
  • Agree a time and resource plan

3. Capabilities

  • Develop and deliver training programmes
  • Embed a customer focused culture
  • Review the identification and support of vulnerable customers

4. Product Governance

  • Review and approve products and services
  • Identify the target market
  • Assess fair value

5. Data and MI

  • Review existing data sources
  • Identify data gaps within your firm and the distribution chain
  • Develop insightful MI dashboards and reporting routes

6. Outcomes Testing

  • Define what good outcomes look like for your customers
  • Assess your products and services relative to those outcomes
  • Execute the change plan

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For more on Consumer Duty, please contact us or to submit Request for Proposal documents, use the link below.

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