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Consumer Duty

The FCA’s new Consumer Duty represents a paradigm shift in expectations in the treatment of retail customers across the whole of the Financial Services sector.

From our work to date with clients and engagement with the FCA we understand the complexity and challenges faced by firms as they not only demonstrate compliance but achieve the shift to a more proactive focus to deliver good customer outcomes and by identifying and preventing foreseeable harm before it can crystallise. Compliance with Consumer Duty is not a finite exercise, and firms will need to evolve and keep evolving their approach to product design, pricing, communications and serving and embed this in their ways of working, from the front line all the way through the organisation to the Board.At Deloitte, we have an experienced team covering the different sectors across range of disciplines including Conduct Risk (including former Conduct Regulators), regulatory change management, Internal Audit, analytics coupled with strong credentials, case studies and technology. We would be delighted to support you with your Consumer Duty programmes and beyond.

 

ConductHub: Conduct Risk Analytics- Transcrpt

 

In today's world interactions are becoming increasingly digital. However as voice and in-person interactions decline, the traditional indicators that are used to spot customer and conduct risk are becoming obsolete. The need to protect customers and ensure good outcomes in the digital era is greater than ever and regulatory expectation is increasing with the FCA's Consumer Duty.

ConductHub is our conduct risk analytics toolkit that combines our regulatory expertise with big data analytics and AI. It can be customised to fit any digital journey and identify customers at risk of an unfair outcome.

With ConductHub we can help you calculate the risk of every interaction and automatically trigger mitigating controls in real time. The reporting suite can provide a clear picture of your overall conduct risk and the effectiveness of your digital controls.

Let's look at Alex, who is applying for an unsecured loan on his smartphone. He logs in then quickly flows through the journey to secure a loan. Now let's see what insight ConductHub could bring.

Using ConductHub, we extract the little details about your customer's behaviour and blend them with other sources of data such as transactions, device information and call center history. This way we can see that Alex was recently declined two loans and had also been reading the online FAQ about support for financial difficulty. His average outgoings increased despite no change to his income and the loan amount he applied for was larger than most customers in his cohort. He also moved through the loan journey a lot more quickly than the average user and spent no time reading the legal information.

We can help you identify scenarios like this across your customer base and take it a step further by building real-time interventions into your digital journeys. This will help you better support customers like Alex to reach good outcomes.

ConductHub: let us change the way you manage digital conduct risk and meet your consumer duty obligations.

ConductHub: Conduct Risk Analytics

How do you take a data-driven approach to ensuring good customer outcomes across millions of digital interactions?

ConductHub is our conduct risk analytics toolkit that combines our regulatory expertise with big data analytics and AI. We can help you calculate the risk of every customer interaction, trigger preventative digital controls, and report on the overall conduct risk of your customer base.

Cross-sector insights

Integrating Consumer Duty into COLL value assessment frameworks | Deloitte UK

Key considerations for firms in relation to integrating the Consumer Duty and the latest regulatory focus areas in existing COLL value assessment frameworks.
Perspective
5 minute read

Consumer Duty: Anti-Financial Crime Program Implications | Deloitte UK

The new Consumer Duty (the Duty) is the Financial Conduct Authority’s (FCA) package of measures, which sets out higher and more defined standards to protect financial service consumers in retail financial markets. The Duty requires firms to evidence that they are delivering on the overarching Cross-cutting rules[1] and Four Customer Outcomes (Outcomes).[2] At a high level, the Cross-cutting rules set out good customer outcomes that are expected to be delivered, while the Outcomes provide the regulators expectations across the firm’s customer relationships.
Perspective
5 minute read

Evidencing Consumer Duty compliance: shedding light on the FCA’s data expectations | Deloitte UK

Board members, senior executives, Consumer Duty champions, and Consumer Duty (the Duty) monitoring and reporting leads.
Perspective
5 minute read

Improving Customer Outcome Testing | Deloitte UK

Against a backdrop of heightened regulatory expectations regarding the fair treatment of customers, this new report provides practical guidance for firms on strengthening their firm’s approach to customer outcome testing.
Research
minute read

Embedding the Consumer Duty into your culture | Deloitte UK

Board members, senior executives, Consumer Duty champions, and those in in-house legal teams, remuneration policy committees, learning and development functions, and other teams involved in the implementation and ongoing monitoring of the Duty.
Perspective
5 minute read

Consumer Duty assurance: how to evidence your compliance and good customer outcomes? | Deloitte UK

Firms and Boards will have to assess their Duty compliance by the end of the implementation period on 31 July and on an annual basis thereafter. To help with demonstrating this, firms are starting to consider the role of external assurance and how it can fit in with internal assurance and other work being carried out. This blog discusses why firms should consider assurance as part of their Duty toolkit and explores how organisations can use different levels of assurance to navigate their regulatory requirements.
Perspective
5 minute read

Episode 34: The New Consumer Duty – raising consumer standards of care | Deloitte UK

The Financial Conduct Authority has published its final rules for its new Consumer Duty. The Duty raises the standards of consumer protection in retail financial markets.
Research
minute read

Consumer Duty – A potential stalemate? | Deloitte UK

The expectations around information sharing up and down the distribution chain is a key pillar to implement the new Consumer Duty requirements. Quality data and Management Information plays a fundamental role to support firms to monitor, assess and evidence that they are delivering good customer outcomes.
Perspective
5 minute read

The Consumer Duty: the ‘Swiss Army knife’ of financial regulation

Read more

Retail banking and lending

The FCA’s action plan on cash savings: the Consumer Duty bares its teeth | Deloitte UK

The FCA’s Cash savings market review and action plan (the Review) provide the first insight into its approach to supervising the Consumer Duty (the Duty). The approach will be assertive and data-led. The FCA will aim to identify practices that may not be delivering good outcomes for customers quickly and pursue them through data requests, interventions and, where necessary, disciplinary actions.
Perspective
7 minute read

Pricing competition in UK retail banking: six key forces at play for 2023 | Deloitte UK

As inflation and interest rate hikes continue to shake up the UK retail banking and building society market, the competitive landscape in 2023 is intensifying.
Perspective
5 minute read

Wealth and asset management

EU manufacturers in the post-Consumer Duty UK fund distribution market | Deloitte UK

In the wake of the UK FCA Consumer Duty value assessment rules, EU firms who distribute into the UK are questioning what their obligations are in this area.
Perspective
5 minute read

Deloitte's IMW Consumer Duty Survey: The Results Are In | Deloitte UK

Investment management and wealth Consumer Duty Survey results summary
Perspective
5 minute read

The UK Consumer Duty Value Assessment Vs EU Undue Costs Rules… finding the leverage | Deloitte UK

Post the UK Consumer Duty implementation deadline in July this year, UK distributors are required to gather all relevant information they need from manufacturers to assess the value of the products they distribute to the end clients.
Perspective
5 minute read

Uncovered: Consumer Duty and CASS | Deloitte UK

Explore the implications of the new Consumer Duty and its connection to CASS requirements, starting from the payment of bank interest earned on client money balances held under CASS 7.
Perspective
5 minute read

Get in touch

Cindy Chan

Managing Partner
+44 (0)20 7303 5836

David Clements

Partner
+44 (0)11 7984 1199

Christopher Jamieson

Partner
+44 (0)20 7303 7996

Lyndsey Fallon

Partner
+44 (0)16 1455 6084