IFA: The FCA’s Consumer Duty challenge is changing shape

Consumer duty Recordsure

Recently featured in the IFA Magazine, Joe Norburn, CEO at TCC Group (TCCRecordsure and Momenta) , outlines how the FCA’s expectations under the Consumer Duty are evolving, with a clear shift towards evidencing customer outcomes rather than simply reporting on implementation progress. As firms enter a more mature phase of oversight, robust monitoring, data analysis and auditability are becoming critical to demonstrate that outcomes can withstand regulatory scrutiny. 

 

The article emphasises that management information alone is no longer sufficient. Firms must be able to interpret and validate what their data is actually 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 – ensuring that the Consumer Duty is 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.” 

 

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