What happened?
Featured Money Marketing, Joe Norburn, CEO of TCC Group, explored how the FCA’s latest guidance on supporting customers through challenging times reinforces the principle of preventing foreseeable harm under Consumer Duty. The article highlights that firms should look beyond conventional measures of customer detriment and consider emerging behavioural indicators, such as customers delaying financial decisions, reducing cover or disengaging from communications.
The article also examines how fair value assessments need to evolve over time. A product that delivered fair outcomes when it was launched may no longer meet customers’ needs if their financial circumstances have changed, even where the product itself has not.
Why does it matter?
The FCA’s direction of travel suggests that firms must take a more proactive and dynamic approach to Consumer Duty. Rather than waiting for evidence of harm to emerge, organisations are expected to monitor customer outcomes continuously and respond to changing risks as market and economic conditions evolve.
Firms that regularly review suitability, fair value and customer outcomes, while acting on early warning signs of potential harm, will be better positioned to demonstrate Consumer Duty compliance and deliver good outcomes for customers.
This reflects a broader shift in regulatory expectations: preventing foreseeable harm is no longer just about addressing known issues, but about identifying and mitigating emerging risks before customers are adversely affected.
Supporting sources
- FCA remuneration reform explained: what CP26/27 could mean for firmsAnalysis & Perspectives · September 2, 2026
- IBS Intelligence: Why financial services firms face growing AI governance scrutinyAnalysis & Perspectives · September 2, 2026
- FCA CP26/28: What the AIFM regime reforms mean for wealth managers and firmsRegulatory Horizon · September 2, 2026
- Will Value for Money assessments change how advisers compare pension providers?Regulatory Horizon · September 2, 2026
- BankingTCC helps retail banks, challenger banks, building societies and specialist banking providers strengthen governance, manage financial crime risk and demonstrate good customer outcomes. Our specialists support Consumer Duty, remediation, regulatory transformation, FCA intervention and compliance assurance programmes through advisory, managed services, specialist resourcing and technology-enabled compliance. With more than 25 years of experience supporting FCA-regulated firms, we help banks respond confidently to regulatory scrutiny while strengthening operational resilience and customer trust.
- General Insurance & ProtectionTCC helps insurers, brokers, MGAs and protection providers evidence fair value, strengthen customer outcomes and identify emerging customer harm. We assess product governance, claims performance, distribution oversight and vulnerability risks, helping firms create regulator-ready evidence, improve operational performance and demonstrate that products and services deliver value throughout the customer lifecycle.
- Lending & Consumer CreditTCC helps consumer credit firms evidence good outcomes, strengthen affordability and vulnerability frameworks, and manage complaints, remediation and regulatory risk. We support lenders with practical, regulator-ready compliance programmes that improve governance, customer treatment and operational resilience.
- Motor FinanceTCC helps motor finance lenders, brokers and providers assess redress exposure, prepare for large-scale customer reviews and strengthen complaints, affordability and Consumer Duty frameworks. We combine regulatory advisory, managed operations, specialist resource and technology-enabled assurance to deliver consistent customer outcomes, robust governance and regulator-ready evidence under heightened FCA scrutiny.
Reviewed by Joe Norburn, CEO – TCC Group