Twelve Days of Consumer Duty #8: next steps after implementation plans

It’s day 8 of our Twelve Days of Consumer Duty exploring key questions midway through firms’ implementation journeys.  

Today’s question

“We’ve signed off our implementation plans.  Now what?”

The answer

Now your implementation work begins.  Your delivery against your plan will require:

• The implementation of an awareness and training programme.  This is key and should be an early action.  Effective implementation relies on people at every level of your organisation really understanding the Consumer Duty and embedding it in the firm’s culture and day-to-day activities.  This is what the FCA means when it talks about achieving a cultural shift as well as embedding “root cause” analysis.  Remember that a change programme involves framework and process but relies heavily on culture and behaviour changes to be truly effective.
• A review of products, services and processes, including to determine whether they are within or outside scope.  Assess each product’s entire lifecycle to pinpoint areas of risk.  Ask yourself: what’s the foreseeable harm?  What does it mean to act in good faith here?  How can you support customers to achieve their financial objectives?
• The definition of good/bad consumer outcomes for each of your products and services.
• Potential governance and controls uplifts, including for testing and monitoring outcomes.

You’ll need to keep your scoping under review as the project progresses, considering any developments in your business and changes to the FCA’s rules and guidance.

Don’t worry if you need to adjust your implementation plan.  It’s intended to be a living document, not set in stone after Board sign-off.  Instead, your focus should be on keeping your Board and senior managers focused so they can engage with the FCA when it comes knocking.

Want more?

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