Consumer Duty – from project to practicality

After the race to the Consumer Duty implementation finish line we all deserved a break over summer. But we’ve only reached the end of the beginning. The challenge now is to move from project delivery to integration, embedding and day-to-day management. And with the FCA already demonstrating the use of the Duty in its day-to-day supervision, it’s important not to be left behind.

Our consumer duty webinar looked at how to embed the Duty into business as usual – from broad principles to detailed requirements – and ultimately to make the new annual reporting requirement a natural output of your control framework. We covered specific challenges we’ve seen in firms so far, and highlighted what the FCA will expect to see, including:

  • policies and procedures (including remuneration and incentives)
  • training and competence
  • compliance monitoring
  • management information
  • governance and the role of the Consumer Duty Champion.

We’ll also reflected on the wider cultural challenge of embedding principals-based regulation, and looked at lessons learnt from regulatory change in recent years.


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