Compliance Briefing — July 27, 2022
The UK Financial Conduct Authority finalised its Consumer Duty rules on 27 July 2022, requiring firms to evidence customer outcomes, product governance, and data monitoring by phased deadlines.
Executive briefing: The FCA released Policy Statement PS22/9 and Finalised Guidance FG22/5 on 27 July 2022. Firms must deliver good outcomes across four duty outcomes (products and services, price and value, consumer understanding, consumer support) with implementation milestones through July 2024.
Key compliance checkpoints
- Board oversight. Secure board approval of implementation plans and annual attestations that Consumer Duty obligations are being met.
- Product governance. Assess product and service design, target markets, and value assessments to ensure fair value.
- Data monitoring. Develop metrics and MI to evidence consumer understanding, support quality, and outcome testing.
Operational priorities
- Implementation roadmap. Align cross-functional workstreams to meet closed-book and open-product deadlines (July 2023 and July 2024 respectively).
- Systems upgrades. Adapt CRM, complaints, and servicing platforms to capture outcome indicators and escalation triggers.
- Training programmes. Deliver role-specific training on the Duty, including frontline staff, product teams, and compliance monitoring.
Enablement moves
- Implement dashboards for Consumer Duty MI with drill-down capability by customer segment and channel.
- Embed fair value assessments into product lifecycle governance and pricing committees.
- Update third-party servicing contracts to reflect Duty expectations for consumer support and data sharing.
Sources
Zeph Tech partners with FCA-regulated firms to track Consumer Duty MI, fair value assessments, and implementation milestones.