What happened?
In an article featured in IFA Magazine, TCC Group CEO Joe Norburn explores how the FCA’s Consumer Duty is entering a mature phase. Compliance is moving beyond initial implementation to a stage where the regulator demands clear, demonstrable evidence of positive client outcomes in daily practice.
This shift requires boards and executive teams to apply deeper subjective judgement, actively interrogate their management information, and move away from over-reliance on process-based checklists.
Why does it matter?
The mature phase of Consumer Duty means firms cannot rely on the strength of their written policies alone. Boards must apply rigorous judgement to prove that customers are receiving fair value and appropriate support, requiring highly detailed, empirical management information to back up any compliance assertions.
Supporting sources
Frequently asked questions
How is the FCA's approach to the Consumer Duty changing?
The FCA is moving from evaluating implementation frameworks to checking for demonstrable, data-backed evidence of actual customer outcomes in day-to-day operations.
What is the board's responsibility in the mature phase of Consumer Duty?
Boards must move beyond reviewing process metrics and apply robust judgement, actively challenging management information to ensure and prove that customer outcomes are consistently positive.
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