Summary
What this article covers in 30 seconds
- Consumer Duty oversight is moving towards evidence of customer outcomes.
- Management information alone is no longer enough.
- Firms must interpret and validate what their data shows about understanding, support and value.
- Audit trails and decision-making evidence are becoming more important.
- Boards need to move from process reporting into judgement.
Recently featured in IFA Magazine, Joe Norburn, CEO at TCC Group (TCC, Recordsure and Momenta), outlined how the FCA’s expectations under the Consumer Duty are evolving.
The FCA is shifting towards evidencing customer outcomes rather than simply reporting on implementation progress. As firms enter a more mature phase of oversight, monitoring, data analysis and auditability are becoming critical to demonstrate that outcomes can withstand regulatory scrutiny.
From management information to defensible insight
Management information alone is no longer sufficient. Firms must be able to interpret and validate what their data is showing about customer understanding, support and value, and respond effectively when risks emerge.
This places increasing importance on consistent oversight, clear audit trails and the ability to evidence decision-making. The Consumer Duty needs to be supported by tangible, defensible insight into customer outcomes.
Joe commented: “The next phase of the FCA’s Consumer Duty isn’t about what firms say they’re doing but about what they can evidence. Boards are being asked to move beyond process and into judgement, where demonstrating good outcomes is far more complex than simply reporting activity.”
Frequently asked questions
Expectations are shifting towards evidencing customer outcomes rather than simply reporting implementation progress.
Firms must interpret and validate what their data shows about customer understanding, support and value, and respond when risks emerge.
He says boards need to move beyond process and into judgement, evidencing good outcomes rather than simply reporting activity.