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Consumer Duty View May 2024


Firms now have under 3 months to meet the 31 July 2024 deadline by which (1) firms need to have completed implementation of the Duty for closed products, and (2) Boards need to have reviewed and approved the first annual report setting out the results of Consumer Duty monitoring and compliance. The annual board report is a hot topic and the FCA has made it clear that it expects Boards (and their champions) to engage with their firms as part of the annual report process and proactively challenge its contents.  

We are seeing a lot of focus on reporting governance and monitoring data. When evaluating whether there is sufficient monitoring of good consumer outcomes, firms should consider relevant mapping for end-to-end customer/product journeys, understand the key risks at each stage, and be looking at data that assures Boards that the risks are understood and customers are receiving good outcomes throughout the journey.