- What outcomes the firm is delivering for its customers.
- Whether the firm is meeting the requirements of Principle 12
- Whether the firm’s business strategy is consistent with Principle 12
- There should be details about the monitoring activities. Owners, how it’s conducted, output from monitoring, issues identified and documented action plans.
- The report should consider how future business plans should reflect the obligations of the duty and whether they allow for full and effective compliance and whether the documented business strategy needs to be changed or updated.
Vulnerable customers should be included in the report:
- How you identify them.
- Whether staff are sufficiently trained to recognise and respond to vulnerability.
- How you document vulnerability on your system and how you monitor the outcomes you deliver to vulnerable customers, for example, that they receive the same outcomes as customers without vulnerable characteristics.
- MI is key so the MI derived from monitoring activities should drive the report summary and conclusions to be drawn from monitoring activities. Don’t forget to include feedback from customer surveys and reviews.
- Provide evidence to prove what you are doing to deliver good customer outcomes.
- The Board must be able to ask themselves ‘Does this process actually work?’ so the information in the report must enable them to answer this question.
- The Report should outline where your changes have been effective and where you have made assumptions, and where you have more work to do
- Can the Board be satisfied from the monitoring output that vulnerable customers are being correctly identified and supported? Where is the evidence ?
- If you’d done work in this area, what has been done and what changed as a result?
As we’ve already said, getting the Consumer Duty embedded into the business isn’t a ‘once and done’ job, it’s ongoing with continual improvement. So, don’t expect to have a ‘green’ Board Report first time around. The FCA won’t trust a ‘green’ report first time around anyway, they will expect to see some amber and red. However, they will also expect the report to highlight anything that needs remediation and will expect to see suitable metrics, context and commentary.
The contents of the Report should be supported by data, metrics, examples and case studies if available. Feedback/pushback from NEDs or the CDC should be included in the report to evidence that the Board are being challenged in their delivery of the Duty. Don’t forget to minute the Board Meeting and the review/signing off the report