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Key takeaways from the FCA’s recently introduced Consumer Duty


At the end of August, one month on from the introduction of the FCA’s Consumer Duty for current credit products and services, Thistle highlighted some of the key points for credit firms to consider. 

Where are firms up to?

In our conversations with credit clients, we have seen that:

The Good

  • Most firms we work with have partially or fully embedded the Consumer Duty, including the necessary policies, procedures, governance and training.
  • Most firms we support have been able to implement the Consumer Duty successfully and are now processing and reviewing the sets of Management Information (MI) selected to monitor firms’ performance against the new Customer Outcomes. It was encouraging to see relevant MI being produced, but we would remind firms that the value of MI and data is only as good as the decisions and actions taken based on it. 

Improvement required

  • We have noticed that some firms are struggling with the scale of change required to their business processes, oversight, and monitoring frameworks.
  • Some remain confused over the extent to which they need to apply the Consumer Duty where they are not directly involved with retail clients, and find the application of the fair value outcome most challenging.
  • Some still have some work to do to embed the duty into BAU.

What the FCA expects   

Now that the Consumer Duty is in place, the FCA will be gathering information to support its assessment of the extent of credit firms’ compliance with Principle 12, the cross-cutting rules and the achievement of the four outcomes for retail clients.

It’s not too late for firms to consider and work on their Consumer Duty arrangements, and indeed they may wish to consider carrying out post-implementation reviews to secure the continual improvement that the FCA has said it will be looking for.