In a recent Money Marketing opinion piece, Joe Norburn, CEO of TCC Group (TCC, Momenta and Recordsure), explores how the FCA’s latest guidance reinforces a core Consumer Duty expectation: firms should proactively identify and address foreseeable harm before it emerges through complaints, arrears or other traditional indicators.
The article highlights how changing customer circumstances can affect product suitability, value and outcomes over time. As financial pressures continue to evolve, firms need to look beyond conventional metrics and consider more subtle signs of customer vulnerability, disengagement or changing behaviour.
“A product that offered fair outcomes a year ago may still meet its original design criteria but no longer work in practice for customers with less financial headroom or reduced resilience,” comments Joe.
For Recordsure, this underscores the importance of ongoing customer monitoring and insight. Identifying potential risks early through customer interactions and behavioural trends can help firms respond before harm occurs and demonstrate that they are delivering good outcomes in line with Consumer Duty expectations.
Ultimately, the article argues that compliance is no longer about periodic reviews alone. Firms must continuously monitor customer outcomes, challenge assumptions and adapt their approach as customer needs and regulatory expectations evolve.
