Figure of eight in purple ribbon for International Women's Day

The importance of embracing equity as a business #InternationalWomensDay #EmbraceEquity

Often the words equality and equity are used interchangeably. But this year’s International Women’s Day campaign – which culminates today on Wednesday 8th March – shines a spotlight on the real difference in their meaning. 

So, we’re keen as a business to explore the importance in understanding this distinction.

The aim of this year’s International Women’s Day theme #EmbraceEquity pushes the world to talk about why the well-coined phrase, ‘equal opportunities’ doesn’t fit the bill.  

At the nub of this important campaign, lies the key message that everyone requires different components to be successful. And that’s where equity is vitally different to equality. Providing everyone with what they need to be successful and acknowledging that as individuals we all have different needs is the first step to real gender equity. 

Equity acknowledges that as people we all start life in different places. 

Equity can be defined as giving everyone what they need to be successful. In other words, it's not giving everyone the exact same thing. If we give everyone the exact same thing, expecting that will make people equal, it assumes that everyone started out in the same place - and this can be vastly inaccurate because everyone isn't the same.

The concept of 'fairness' can get tricky as it's often assumed that 'being fair' means that everybody gets the same thing. Often, this has been taught when we were growing up, but 'fairness' really only works when we're all the same to start out with.

International Women's Day website

This is a conversation that touches all aspects of society.

And one that has inspired us to continually consider and review the support, policies and social committees we deliver and champion with our team members. And at various points in all our lives we’ll be approaching issues from different viewpoints – so we’re keen to acknowledge and support this as a business through our internal policies. 

For example:

  • Our menopause policy aims to break the taboo in the workplace – we want everyone to be able to talk about it openly and without embarrassment and explain to those who don’t know, how this transition in a woman’s life is often not always an easy one.  The changing age of the UK’s workforce means that between 75% and 80% of menopausal women are in work. And research shows that the majority of women are unwilling to discuss menopausal related health problems with their line manager, nor ask for the support or adjustments that they may need. Through our policy we want our team members to feel supported to improve their time at work and know that as a business we understand the challenges they’re facing and will help them through this time. 
  • We’re also committed to supporting working parents and knowing that flexibility is key to creating a successful work-life balance. Our team members have the choice of working from home, the office or hybrid as well as flexibility around school drop off and pick up times. 

And striving to advance towards a truly diverse workforce is championed by our Diversity, Equity and Inclusion Committee in collaboration with our Senior Leadership and HR team.

Our vision is simple:

Our workforce is diverse, and diversity of thought is respected and reflected at all levels within the business.  

There is a culture of inclusion, psychological safety and belonging, in which our colleagues feel valued, listened to and free to be themselves.  

Equitable treatment is the norm with policies, processes and structures adapted to reflect this so discrimination is eliminated at all levels. 

And we'll never stop learning.

We’re committed to continually reviewing our approach to ensure we’re a truly equitable employer.  Joe Norburn, Chief Executive Officer at Recordsure explains.

International Women’s Day is an important day for us to mark as a business, not only out of respect and gratitude to the women who have tirelessly campaigned throughout history, but to acknowledge and continue learning from the hard work that continues across society to achieve equity for everyone.

Today provides a natural check in for us to ensure that we're on the right track - we consider our company ethos and policies, and feedback from across the business. Our focus on equity goes far beyond International Women’s Day alone, it’s something we’re committed to achieving for all our colleagues every day.

Joe Norburn, CEO at Recordsure

We’ve also been proud to hear our female team members’ thoughts on how our equity values have helped, and continue to help, in their current roles:

As a mum to two young children, finding an employer that values your commitments as a parent is priceless. Working remotely means I can incorporate the school run into my day and my colleagues understand this. This has really helped me create the work-life balance I’ve always strived to have.

I’m grateful to have been given the opportunity to work in a new male-dominated industry - my hiring manager saw my potential beyond my industry credentials, and I've been given the opportunity to grow within the business.

I feel very lucky to have been mentored by an incredible woman who has created two amazing businesses, both in very male dominated sectors.

I feel fortunate and proud to work for senior leaders who embrace diversity and foster a culture of inclusion, psychological safety and belonging. This empowers me in my role within our HR function, knowing that future advancements I propose to our policies and working practices which support diversity, equity and inclusion will receive full backing.

Flexible working policies have allowed me to focus on my career and be there for my family.

Target Why use RegTech to evidence consumer outcomes and achieve Consumer Duty success?

Why use RegTech to evidence consumer outcomes and achieve Consumer Duty success?

Last October, FCA regulated firms were busy preparing for the first step on their Consumer Duty journey ahead of the Halloween deadline for implementation plans.  

Fast-forward three months, and the regulator has now provided their first in-depth analysis of some larger ‘fixed’ firms’ plans in turn giving a clearer picture of their expectations through key findings. 

So, how does this snapshot help your firm implement positive, Duty-focussed change?  

Well, a key area the FCA noted was:

“We saw some plans that suggested firms may have considered the requirements superficially or are over-confident that their existing policies and processes will be adequate.”


Therefore, this short but significant window of time before the 31st of July 2023 can be used to consider whether you have given enough in-depth thought to how you will monitor, and evidence good consumer outcomes – and if you’re not planning on utilising RegTech to support this, then ask yourself why not?  

Deliverability through tech

With the upcoming implementation deadline, firms are realising that embedding the Consumer Duty and monitoring its outcomes is no mean feat, and that resource investment alone isn’t going to provide the level of oversight required to monitor and evidence good consumer outcomes consistently. In its multi-firm review, the FCA did note some effective ways firms can go about this: 

“We noted examples where firms have identified early, and in detail, any resource shortfalls for timely implementation – especially in areas like technology – and have a commitment and plan to address this. Some firms are investing sensibly in support and advice from external experts where this assists and adds value.”


This follows the ‘Zeroes to Heroes’ speech from FCA Chief Operating Officer and Executive Director Emily Sheppard, which detailed how fostering an innovative culture and embracing AI solutions could hold the key to efficiently and intelligently analysing the reems of data firms have at their disposal. 

Utilising AI

And that’s where Recordsure’s ConversationReviewAI can help. This unique solution is founded on intelligent speech analytics to provide enhanced Quality Assurance (QA) in regulated industries. Our proprietary AI models are proven to increase the efficiency and effectiveness of QA teams, ensure consistent QA reviews and evidence QA outcomes while increasing QA oversight to 100%.  

With a wealth of in-built MI, ConversationReviewAI can also form a fundamental part of your firm’s long-term data strategy – another thing the FCA has noted as good practice in its review.  

Next steps

The FCA has been clear in its latest communication that it’ll be keeping a close eye on firms’ Duty implementation in the coming months – with planned surveys for a sample of firms to gauge the progress they’re making, along with targeted engagement with smaller firms.  

With this in mind, if you haven’t yet considered how RegTech can help you monitor and evidence consumer outcomes, now’s the ideal time to adopt a best-in-class tech solution that will help propel your firm to Duty success.  

You can now trial Recordsure’s ConversationReviewAI mortgage market model for free over 30 days. To learn more book an online meeting with Recordsure at a time that works for you. 

Starting line on race track

RegTech for Consumer Duty: three steps to the starting line

The 31st July 2023 is a date firmly stamped in FCA regulated firms’ diaries: from then on, the Consumer Duty will be a regulatory reality for new and existing financial products and services.

But why is the Consumer Duty so hotly anticipated? Simply, because it’s a momentous shift to a much more assertive form of supervision by the FCA, meaning this date is not one that can be filed and forgotten – nor is it merely a finish line that’s just months away. 

In reality, the 31st July 2023 is the starting point to a new evidence-based, outcome-focused era of regulation.

So, with that in mind, we’re highlighting three important steps that firms can take now to get themselves ready for that Consumer Duty starting line.

1. Prepare all team members for the change

By now, many firms will have working groups set up to tackle the changes in policy and processes needed to realign with the Duty’s more stringent oversight standards. And so, it’s more important than ever that everyone – across the entire business – understands why these changes are taking place, and how this will require a long-term behavioural shift, not just compliance with new processes.

The impact of these changes will be felt from the board level to senior management, with the latter likely to oversee its rollout and application in real terms. We also know that a cornerstone of the Duty is to provide support for vulnerable customers, so those colleagues in customer facing roles will need to be trained to spot and identify those characteristics and provide suitable help.

2. Embrace data technology

The FCA has been clear that the Duty is going to be enforced in accordance with their cross-cutting rules. That’s why having oversight of all customer interactions will be a vital piece of the puzzle – allowing potential problems to be pinpointed early on, before they have the chance to crystalise into a serious breach of the Duty regulations.

Currently, it is a resource heavy and costly task for QA teams to gain oversight of all their customer interactions, so random sampling is the only choice. . But it’s becoming more and more clear that this won’t cut the Consumer Duty mustard. 

The good news? There’s already a better way – by utilising data technology. The role AI and tech can play in overseeing all customer interactions, could prove revolutionary for QA teams. By embracing the latest technologies, firms can fully review all customer interactions using AI, in turn focusing their human reviewers’ attention where it’s needed most based on the AI QA outcomes.

3. Move beyond random sampling

Firms that stick with random sampling alone run the risk of not understanding the true trends and context of their customer data and interactions, which ups the ante of not meeting the Duty requirements.

For example, a firm that receives 120,000 calls a month can only review a small percentage of these interactions – around 1,000 a month, through the random sampling method. They may detect a small proportion of problem calls using this small sample but in no way can this paint a true or realistic picture across all interactions.

Under the Duty, having a better, more realistic grasp of your firm’s bad outcomes – by reviewing all the data available to you – will go a long way in helping you transform those bad outcomes into good, and reduce the potential for further bad outcomes in the long-term. 

After all, firms that embrace machine learning to achieve 100% oversight of all their customer interactions will be in an ideal position to proactively identify and rectify signs of risk or consumer harm – a component of the Consumer Duty that really matters. 


Recordsure’s ConversationReviewAI solution is a unique platform for enhanced QA  reviews, with AI QA models trained using 1,000s of hours of financial services specific conversations. Our mortgage market model is based on best-in-class frameworks, and firms can test it out  with a free 30-day trial. To explore this further, book an online meeting with Recordsure at a time that works for you. 

To learn more about the good consumer outcomes that will be expected under the Consumer Duty, watch our webinar ‘Consumer Duty’s good outcomes: understanding the regulatory expectations’ on demand now.

How to improve your treatment of vulnerable customers with AI technology

How to improve your treatment of vulnerable customers with AI technology

The circumstances we’ve faced, not only in this country but also globally, over recent years can seem almost unreal when we take a moment to look back. 

From the Covid pandemic to the current cost-of-living crisis, these truly challenging times show no sign of reprieve for many as we move into 2023.

Testing times

Such challenges have unfortunately led to an increase in the amount of consumers with characteristics of vulnerability – with over one million more customers meeting the criteria than two years earlier. The Financial Lives 2022 survey showed 47% of UK adults had one or more of the characteristics in May 2022 likely due to an increase in the amount of UK adults with low financial resilience. 

And in real terms, the cost-of-living crisis has left many households facing mounting bills, increasing food prices and soaring energy costs– which has only exacerbated the strain on peoples’ purse strings and left many facing financial hardship.

So, it’s clear to see why the FCA’s Consumer Duty is placing such emphasis on providing good outcomes for customers and protecting those that are most vulnerable.

Effective evidencing with AI technologies

Having a robust process in place to identify which of your consumers show signs of vulnerability – bearing in mind that this can happen to anyone at any time throughout their customer journey – has never been more important. 

But how can firms effectively demonstrate this and evidence fair treatment of vulnerable customers? Well, the good news is the FCA has already cited one solution in a recent speech: by embracing the use of AI.

Quality Assurance teams can implement RegTech to great effect when addressing the challenges of vulnerability.

New feature to address vulnerability challenges

Recordsure’s unique ConversationReviewAI product – founded on intelligent speech analytics – now offers a new innovative feature that aligns with your own internal vulnerability QA policies and processes. Combining speech analytics and machine learning with the latest technology, you can apply a consistent approach to vulnerability identification and assessment and revolutionise your firm’s support for vulnerable customers. 

Under the Consumer Duty, the FCA will increasingly be asking for data focused on consumer outcomes with the fair treatment  of vulnerable customers high on their checklist – so firms will need to maximise the oversight of all their customer interactions, with a particular focus on how they are assessing vulnerability.

Want to learn more about how Recordsure’s unique solution can help ensure fair treatment of vulnerable customers? Download our Fair treatment of vulnerable customers information below.
Broadening oversight of customer interactions with tech and AI webinar recap

Broadening oversight of customer interactions with tech and AI

In recent weeks, we brought together Consumer Duty experts, in partnership with the BSA, to consider all things Consumer Duty and what it means for the mortgage market. 

In our concluding webinar of the three-part series, Garry Evans, Recordsure’s Chief Product Officer, and Olivia Fahy, Recordsure’s Senior Product Manager, considered how the sector can use RegTech to effectively support Consumer Duty compliance and provide evidence for the FCA’s “show me, don’t tell me” approach. 

Here we take a whistle-stop tour of the webinar’s highlights, including a closer look at the role that tech and AI can play in helping get the mortgage market ready for the new Duty.

Watch the webinar on-demand:  

A better method of oversight than random samples

To put it succinctly, there are two problems with random sampling – the method currently used by many mortgage Quality Assurance teams: it’s random, and it’s a sample.

By reviewing just a small sample of customer interactions, a large proportion of consumer data is left un-analysed, which can make it difficult to paint a true picture of where real issues may lie. Often, there is the myth that upscaling to review 100% of all customer calls requires a dramatic increase in resource. This scenario may certainly be true if relying on human resource alone, but utilising the right kind of intelligent technology will mitigate this need – and actually give QA teams 100% oversight of customer interactions. In turn, this means their focus can be on those calls that need most attention. Our client evidence suggests that using ConversationReviewAI doubles team productivity.

Speech analytics with a difference

Ensuring good, consistent consumer outcomes will be more important than ever under the FCA’s new Consumer Duty. And that’s where Recordsure’s ConversationReviewAI can revolutionise how QA teams achieve call quality assurance whilst gaining full oversight of customer interactions.

The ConversationReviewAI model leverages machine learning and thousands of hours of manual training by our in-house linguistic analysts. The analysts meticulously examine customer calls and teach the Recordsure AI model to understand the context around the language used in conversations. 

And Recordsure’s unique ‘neural network’ solution goes beyond speech analytics that rely on identifying key words and phrases. Such models often only achieve a true positive for every five false positives. Recordsure’s solution goes way beyond this, with accuracy around the 90% mark.

Effectively oversee 100% of customer calls

To capture your firm’s customer interactions, Recordsure can do this in one of two ways

  • An API straight through to your company’s telephony systems
  • Via an audio capture app which can be used in face-to-face or remote customer conversations

The captured audio is converted to a transcript for analysis and then visually classified by our ConversationReviewAI model, where results can be seen on the Recordsure portal. The AI breaks the call down into key topics  so it’s easy to see what has been discussed when and where. From here, QA reviewers can select from classified topics to align with their checklist and systematically jump to the relevantly themed parts of the audio. The transcript aligns to the selected section so that reviewers can read, as well as hear, their chosen topic and area.

Classifications and beyond

Our AI goes one step further than classification. ConversationReviewAI will break your audio’s classifications down into further individual risk points, so it’s even simpler for the reviewer to check associated areas with the most relevant content.

As 100% of customer calls are reviewed, our model will scale and group calls based on their level of risk, meaning reviewers can spend the majority of their time looking at the most problematic calls. This gives invaluable oversight and also flags high-risk areas whilst allowing a deep dive into specific cases.

This kind of analysis would not be possible via random sampling alone. ConversationReviewAI’s scope to find trends and themes in interactions gives the tools to address the root cause of problem areas, so continuous improvement across your customer journeys can be made.

AI and tech’s role for the mortgage sector

  • Catching the errors: With mortgage teams under increasing pressure, being able to evidence the information supplied to customers for both remediation and regulation purposes is key. Taking proactive action now to gain a deeper understanding of all the advice being given to customers will prove invaluable in the future.
  • Complying with the Consumer Duty: The step-change in regulation that the Consumer Duty will bring should not be under-estimated. More and more the FCA talks about firms embracing AI and using data to gain greater oversight of customer interactions. Having this level of oversight is no longer a pipedream and is achievable, so the FCA will be keen to see this in practice. 

Breaking down barriers

ConversationReviewAI’s sophisticated system supports natural language. The best customer conversations can’t be scripted, and our contingent model is trained at analysing just that. It’s designed specifically to analyse organic, unstructured conversation – the model’s ‘engine’ has been taught from thousands of hours of transcription and annotation.

As Recordsure is used by a number of high street banks and mortgage associations, we have created a ‘best in class’ model that the mortgage market can literally plug in and go. This means no lengthy induction process, upfront investment, or leaps of faith from firms.

Our free 30-day trial aims to show just that. If you’d like to learn more about how Recordsure’s ConversationReviewAI can help transform your QA team’s call reviews, get in touch today.


Artificial Intelligence's role in the Consumer Duty regulations

Accelerate a positive culture: AI’s role in the Consumer Duty’s future

This week we’ve been reflecting on how the financial service industry is personified following the ‘From Zeroes to Heroes’ speech delivered by FCA Chief Operating Officer and Executive Director of Authorisations, Emily Shepperd.

Think Wolf of Wall Street which neatly sums up Emily’s point– a “hedonistic stockbroker… whose main purpose is to con wealthy clients”.

Obviously not a complimentary or trustworthy industry portrayal. And the list goes on of examples where the industry is depicted as either risky and reckless… or the polar opposite – dull and dreary.

And between these two profiles, the sector is often painted in a not-so-positive light.

But let’s cut to the chase, how does big screen portrayal impact on industry culture?

Culture shapes conduct – and it’s conduct that the FCA is keen to overhaul in the new Consumer Duty era. It’s a trickle-down approach. Those at the top shape company ethos and so need to be leading from the front to embrace this change.

And what should those leaders be banging the drum about? It all comes down to good outcomes. This is what Duty champions and boards have been signposted to as the nub of the Duty. And here lies the crux: spotting and supporting customers in need, those that are most vulnerable.

AI is repeatedly highlighted as a tool that can help firms embrace this new culture.

By having holistic oversight of customer data, spotting, and supporting customers when they’re in need becomes a more manageable and evidencable feat for QA teams. Firms that embrace this tac will be able to demonstrate how the Duty’s ethos is at the heart of its customer and business life cycle, as they quickly, succinctly, and concisely analyse customer interactions.

Advance with AI

Using AI-powered tools such as Recordsure’s unique platform for QA compliance reviews means firms can move away from the more traditional random sampling form of quality assurance. Businesses can now futureproof their approach by embracing the actionable insights that AI tools provide. Increase the efficiency and effectiveness of your QA teams and ensure consistency of QA reviews. 

Want to learn more about how AI can help review customer communications and the wider cultural shift? Get in touch today.

Download our whitepaper to explore how AI-enhanced RegTech can make relying on a random sampling approach to compliance reviews a thing of the past – and introduce simplified audit trails with 100% oversight of all client interactions.
AI can help navigate the Duty jungle

AI can help navigate the Duty jungle

Heavy lifting upfront

The phased Duty deadline is on track and the FCA is keen to encourage openness and embrace a pragmatic approach as things develop. The hard work firms are committing to now should mean fewer reactive rules form the FCA in the future.

Industry innovation

Nikhil continued that “the Consumer Duty can help shape a framework for use of Artificial Intelligence (AI) and other new technologies”.

But how can AI help shape your Duty strategy? By embracing RegTech solutions to monitor and evidence consumer outcomes, firms can switch to a more efficient, more sustainable way of working. Spotting the signs of vulnerability and tailoring products to individual needs are all high on the Duty checklist. Couple this with receiving and reviewing accurate customer feedback and data, it’s clear to see how AI will be an integral cog in the Duty machine.

Invest in AI

As Olivia Fahy, Recordsure’s Senior Product Manager recently put it “Firms can either invest in more people or invest in tech to create efficiencies that enable their people to spend their time more productively on what matters.” Using AI-powered tools such as Recordsure’s unique platform for QA compliance reviews means firms can move away from the more traditional random sampling form of quality assurance reviews. Businesses can now futureproof their approach by embracing the actionable insights that AI tools provide to increase the efficiency and effectiveness of their QA teams and ensure consistency of QA reviews. And get Duty ready to monitor for compliance and evidence customer outcomes.
Download our whitepaper to explore how AI-enhanced RegTech can make relying on a random sampling approach to compliance reviews a thing of the past – and introduce simplified audit trails with 100% oversight of all client interactions.
crowd at train station purple RS overlay and icon

Webinar recap: Three things we learned about Consumer Duty compliance

On 31st October 2022, we kicked off an exciting three-part webinar series on the FCA’s Consumer Duty with our first instalment.

We partnered with BSA and TCC to launch our new webinar series on all things Consumer Duty. Our first of three sessions, ‘What is Consumer Duty compliance, and why do I need to take action now?’ offered an insightful guide to the FCA’s Duty.

The panel of Duty specialists was hosted by Recordsure’s Programme Manager, Adeline Han and featured Garry Evans, Chief Product Officer at Recordsure, and TCC’s Consumer Duty expert and Associate Director Neil Dethick.

During the session, our specialist trio broke down the whats and whys of the new rules. We delved into why it’s so important for firms to take these increased consumer care standards seriously – and of course, gave some actionable tips on how you can show the regulator you’re really doing your bit.

So what were the main takeaways?

The Consumer Duty: what’s all the fuss about?

As well as being spookiest day of the year, financial services firms will know that 31st October 2022 marked the first significant milestone on the FCA’s Consumer Duty roll-out. From this point on, businesses need to have their implementation plans finalised, Board-approved and ready for inspection by the FCA.

In other words, firms should have decided by now how they’re going to align their compliance strategy and internal processes with the new regulations. And they need to have answers to basic consumer-centric issues like what a ‘good outcome’ looks like for their customers – and by extension, how this can be reliably measured and evidenced.

Businesses now have until 31st July 2023 to ensure their new and existing products and services are compliant with the Duty’s standards. And then until 31st July 2024 to ensure the same for their closed products and services. This means firms need to be looking very closely at their portfolio and make changes or adjust processes if necessary.

As the Consumer Duty covers almost every aspect of the business lifecycle, right from product design through to client interactions and complaints handling, getting it right long term is going to need a thorough consideration of your approach to customer care at each of these stages.

Point 1: The Consumer Duty isn’t just business as usual – no matter how diligent you’ve been before

It’s true that most businesses already think they’re doing right by their customers. But the reality is that the old guidance many firms are still working to, and the new requirements the FCA has laid out under the Consumer Duty, translate to two very different standards of care.

For instance, the FCA has reported that it commonly finds information being presented in a way that’s misleading or difficult for many consumers to understand properly. Products and services that either don’t offer fair value for money or otherwise offer little in the way of tangible benefits are still being sold to customers.

And it’s exactly these types of issues that the new rules are looking to address. Indeed, far from just being Treating Customers Fairly (TCF) with a new coat of paint, the Consumer Duty signals a new approach to delivering good outcomes and aims to put customers at the heart of every decision that gets made within financial services.

Far from just being Treating Customers Fairly (TCF) with a new coat of paint, the Consumer Duty signals a new approach to delivering good outcomes and aims to put customers at the heart of every decision that gets made within financial services


But not only that: it’s also the clearest statement of intent we’ve had so far regarding the FCA’s shift towards a more proactive, ‘assertive supervision’ model of regulation.

Point 2: The Consumer Duty isn’t just TCF by another name – and business leaders need to get onboard, sooner rather than later

Put simply, it can’t be stressed enough how the Consumer Duty and TCF are completely different initiatives – both in scope and in structure.

For one thing, TCF primarily took the form of principles-based, best-practice guidance meant to help businesses achieve positive results for their customers. The Consumer Duty, meanwhile, is backed by a rigid set of enforceable rules – and so there’ll be much less regulatory wiggle room this time around.

Unsurprisingly, then, the duty will place much more emphasis on outcomes than previous FCA agendas. It’s also backed by strict monitoring and testing requirements – alongside enhanced oversight responsibilities for Boards – to ensure good outcomes are consistently delivered and that firms are continuously taking positive steps towards improvement where needed.

Beyond that, the Consumer Duty marks a step up in terms of governance standards, meaning senior managers and executives will be responsible for maintaining compliance – and directly answerable for what goes on under their watch. At the end of the day, when it comes to outcomes and obligations, the Board and management teams will be accountable for the Duty compliance come August 2023.

These higher standards are also reflected in the new Conduct Rule 6 – mandating firms to ‘act to deliver good outcomes’ for customers – which in layman’s terms means it’s no longer enough to simply do no harm. Under the Consumer Duty, firms, including mortgage providers, must be proactive in making sure consumers receive the best possible results from their products and services, while monitoring and evidencing the conversations.

Point 3: There’s a lot of work to be done (and not a lot of time to do it!)

While every firm will inevitably have its own strengths and weaknesses when it comes to getting Consumer Duty ready, our conversations with clients have revealed a few common areas of concern.

First and foremost, Price and Value outcome: what constitutes fair value, and how can this be quantified? The duty’s focus on proportionality means firms will have to take another look at their charging structures – and this will be extra critical in cases where they’ve charged flat fees until now.

As a quick example, take a 10% flat rate on a mortgage. This would cost £10,000 for a £100,000 loan but exponentially more for a £1m loan – under the new rules, this becomes extremely difficult to justify without proving the larger mortgage required your staff to complete 10 times the work. 

Consumer Understanding outcome, meanwhile, has also been causing some headaches. Because for starters, how can firms be sure their customers genuinely understand the information presented to them? How can this be accurately tested, and how often should these audits be carried out? And finally, given that customers’ financial situations and priorities change over time, how far should businesses go to ensure their customers still grasp the implications of their long-term arrangements?

What’s more, some firms are struggling to grasp how they’ll increase their monitoring and supervision to fit the lofty new standards.

For instance, what kind of MI is needed for these new checks? How can this data be compiled when we need it? How much can we rely on it to tell the whole story? What kind of processes and compliance tech firms need to address the gaps in conversation monitoring and evidencing?

And on a more fundamental note, how can the lessons learned translate to effective policy or process change?

Recordsure collaboration with Grant Thornton News

Recordsure and Grant Thornton strategic collaboration to transform customer conversation monitoring

News Release

We’re delighted to announce a new collaboration with leading professional services provider Grant Thornton to support Consumer Duty implementation and compliance across the UK financial services industry. This strategic collaboration is set to transform customer conversation monitoring for FCA‘s Consumer Duty compliance.

Consumer Duty: transforming customer conversation monitoring

Leverage artificial intelligence and machine learning to achieve regulatory requirements

Financial services businesses need to focus on ensuring positive consumer outcomes. Increasing pressure on consumer finances is adding to the higher standards required by the FCA’s Consumer Duty. 

The new regulations stipulate ongoing monitoring of retail customer outcomes. You must monitor key elements and set up continuous feedback loops into governance forums to ensure these standards are achieved, and that appropriate action is taken if not. Reliance on random sampling of customer conversations doesn’t provide sufficient oversight to be confident of Consumer Duty compliance. 

To help you enable this monitoring, we’re collaborating with Recordsure on a new service that makes it easier to get the right quality assurance processes in place. This service brings together our own expertise in data, regtech, automation, and digital transformation with Recordsure’s market-leading artificial intelligence.

Oversight of all customer conversations

Random sampling of customer conversations throughout the customer journey isn’t a reliable quality indicator – and presents a significant hidden conduct risk, both at individual and systemic levels. It’s not an acceptable approach when there are viable solutions available for detecting harm.

Strategic data-driven AI and machine learning

Working together, we’ll enable regulated financial services organisations to automate oversight of all customer conversations and support subject matter experts to review identified risks. Implementing compliance analytics to highlight and better understand non-compliant conversations directly feeds into individual and team coaching, and improves customer outcomes by helping to identify possible systemic issues.

Niresh Rajah, Head of Data, RegTech & Digital Advisory Practice at Grant Thornton UK LLP comments on the strategic collaboration.

Ensuring firms are able to discharge their consumer duty obligations is a complex set of activities and requires a data driven approach underpinned by sophisticated machine learning and artificial Intelligence tools and techniques. This exciting collaboration allows us to support our financial services clients through the Consumer Duty journey by combining our data management, data analytics regulatory change and regtech expertise and experience with Recordsure’s leading machine learning platform

Niresh Rajah, Grant Thornton UK LLP

Adrian Crean, Partnership Director at Recordsure and TCC Group is thrilled about this new strategic collaboration and looks forward to working with Grant Thornton and bringing more benefits to our clients:

We’re thrilled to launch this new strategic collaboration with Grant Thornton. Both organisations, Grant Thornton and Recordsure, have a strong belief in fair customer treatment, and conviction in helping our clients power their regulatory and consumer oversight obligations with market-leading technology and data, to deliver better customer outcomes.

Adrian Crean, Recordsure and TCC Group
Adrian Crean-Recrodsure-Partnership-Director

Find out more about this collaboration and the efficiencies our Compliance Analytics AI solutions can bring to your Quality Assurance teams. 

RS consumer duty compliance webinar 31st october 2pm

Consumer Duty compliance: why now’s the time to take action

More than simply the latest in a long line of legislative tweaks, the FCA’s ambitious Consumer Duty represents a paradigm shift in the way consumer protections, oversight and compliance evidencing are managed and regulated across the whole of the financial sector.

The new rules are intended to significantly raise standards of customer care and will require businesses to prioritise the needs of the consumer at every step of the decision-making process, spanning the entire business cycle from product and service design through to customer interactions and complaints handling.

And not only that: the regulator will expect businesses to be able to evidence that they’re adhering to a customer-first approach. It’ll also want to see how any emerging risks are being dealt with promptly and that less-than-stellar outcomes form the basis for meaningful change going forward.

The Consumer Duty, then, signals an evolution from the previous ‘Treating Customers Fairly’ doctrine, encouraging firms to do more than simply avoid causing harm and instead actively work to help customers achieve their financial goals.

Why is Consumer Duty compliance so critical for FCA-regulated firms?

The Consumer Duty is emblematic of the FCA’s new ‘assertive supervision’ approach to regulation, pledging to be more ‘proactive’ – as opposed to primarily reacting to issues that have already occurred – and quicker to intervene in the face of emerging risks when necessary.

The duty’s overarching Consumer Principle mandates firms to ‘act to deliver good outcomes’ for customers, whilst the Cross-Cutting Rules and Four Outcomes set out the FCA’s expectations for behaviour towards consumers and the standards that businesses must strive to achieve, respectively.

But equally significant is the Consumer Duty’s emphasis on a ‘show me, don’t tell me’ approach to regulation, whereby businesses will have to routinely evidence:

‒ They’re clear about what constitutes ‘good outcomes’ for their firm

‒ Good outcomes are being consistently achieved

‒ Lessons are being learned, and improvements are being made, when they fall short

It’s undeniable that these stringent consumer protection rules will look to ensure vulnerable customers are better protected – however, implementing and sustaining this considerable step up in monitoring requirements is sure to present a challenge for even the most dutiful compliance teams.

For example, how can firms be sure they’re able to identify signs of vulnerability when relying on random sampling checks? And how can they be sure they’re treating the root cause of any inefficiencies, not just the symptoms?

Want to learn more? Looking for answers to your Consumer Duty compliance questions?

For expert advice on how to maximise your teams’ capacity and optimise your risk management strategy in the face of ever-increasing regulatory obligations, we invite you to view our exclusive webinar from Monday 31st October.

During this productive session, we outlined the main objectives and thought processes behind the FCA’s Consumer Duty regulations – and assessed what maintaining compliance with these impactful new rules will mean for your compliance processes.

Our panel of compliance experts shared some actionable tips on how you can meet your Consumer Duty oversight and risk monitoring requirements, alongside valuable guidance on building a robust compliance strategy that’s built to last.

The discussion ended with a Q&A session, during which our specialists addressed specific points of interest from attendees.

Watch our webinar on demand for critical insights from our compliance experts – and have your most pressing questions answered!

‘What is Consumer Duty compliance, and why do I need to take action now?’

Hosted by Recordsure Programme Manager Adeline Han, the panel for this not-to-be-missed session also featured:

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