Twelve Days of Consumer Duty #9: the Board Champion’s role

It’s day 9 of our Twelve Days of Consumer Duty exploring key questions midway through firms’ implementation journeys.  

Today’s question

“Help – I’m the Board Champion!  Am I in the firing line if the FCA aren’t happy?”

The answer

The Champion isn’t on the hook for your Consumer Duty implementation nor for every breach of the Consumer Duty.  The Champion isn’t a prescribed responsibility under the SMCR and does not affect existing Senior Manager obligations or the Board’s collective responsibility.

Instead, the Champion’s role is to support the Chair and CEO in ensuring that the Consumer Duty is raised regularly in all relevant discussions, and the Board is challenging the firm’s governing body and management on how it is embedding the Consumer Duty on focusing on customer outcomes.

There are parallels here with other occasions on which the FCA has called out specific issues as particularly worthy of Board engagement; but here the FCA is asking firms to nominate a specific person to ensure this engagement occurs.

And the FCA isn’t prescriptive about how firms implement this guidance to appoint a Champion.  Firms should apply their judgment in view of their size and business structure.  This is clear from the FCA’s early-doors guidance on the subject.

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