UK Finance has outlined four key elements firms should be focussing on when building their Consumer Duty implementation plans. These are:
- definition of the target end state as an input to the gap assessment – to define a high-level target state, firms should define how they will measure, disclose and test each of the four Consumer Duty outcomes;
- a focus on evidencing outcomes – firms should use a top-down approach to identify what data they need to measure these outcomes;
- considering governance central to how all the elements of Consumer Duty come together – UK Finance believes this will require several changes including to the SMCR framework to ensure responsibility for the Duty is appropriately embedded and changes to supporting processes and procedures; and
- remediating products and services to meet the enhanced standards – the FCA expects firms to take a risk-based approach but accepts that full remediation is unlikely given the timelines for implementation.