Consumer Duty – Day 2 Enhancements

Consumer Duty implementation - Day 2 enhancements

This year many firms focused their Consumer Duty implementation activity on ensuring they were substantively compliant for open products by the end of July 2023. Firms are now taking the opportunity, post the deadline, to focus not only on achieving compliance for closed products, but also on making enhancements to activity already undertaken for open products. This ongoing activity ensures firms fully embed Consumer Duty, and reach full compliance, where resource constraints or longer delivery timelines may have prevented earlier completion.

It is with this in mind that Huntswood has decided to produce a series of short updates, focusing on enhancements that firms can continue to make to achieve full compliance.

Value for Money

Many firms have undertaken high level value for money assessments for each open product, but there are ways to enhance these assessments to ensure they are robust and stand up to regulatory scrutiny.

1. It is important that value for money assessments take account of the other key outcomes of Consumer Duty. For example, it is not possible to demonstrate a product is delivering value to the customer if it is being sold to people outside of its target market, or there are high volumes of complaints, or customer communications are not sufficiently clear about the product exclusions
2. It is not all about the narrative, it is important to use the right data at the point of the assessment to ensure you can tangibly evidence customer value, price and comparative cost in the market.
3. It is important to get the right subject matter experts involved, so you are taking a critical look at the product. By looking at it with a critical eye, you can identify points of consideration and evidence why you are comfortable the overall proposition delivers value for money to a customer. In many cases this is just about evidencing key discussions and conclusions that you may have already had in governance meetings on the product.