Consumer Duty Flyer - Flipbook - Page 6
The Consumer
Duty journey
‘we expect firms to use the implementation
period fully and to be able to demonstrate
progress when asked’
CP 21/36 ,13.15
‘We would expect a firm’s board, or
equivalent management body, to consider a
report from the firm assessing whether it is
acting to deliver good outcomes for its
customers which are consistent with the
Consumer Duty, at least annually.’
Consumer Duty is a journey, not a destination. An ongoing process of monitoring, assessment
and improvement.
Building the programme from this perspective enables the controls to be embedded and operationalised,
at each stage. Which reduces the administrative load, and facilitates a smooth BAU integration.
A top-down approach will quickly
The combination of top-down and
As the project will require
The
FCA expects to have final
ruleswhich
outpresent
by the
July 2022,
andworkstreams
for firms
identify products
bottom-up
will to
significant resource from across the
highest risk. This enables project
accelerate the implementation
organisation, it is important to
implement
the requirements
end of April 2023.
resourceby
to bethe
prioritised.
phase.
‘make it real’ for stakeholders, and
secure buy in.
Project
initiation
Scoping
Triage
Deep dive
Implementation
Embedding
CP21/13, 14.14
It is important to establish which
products will be in scope, which are
live or back-book, and what role
the firm has (manufacturer or
distributor)
The bottom-up deep dive will
drill into the detail and identify
what are the specific issues of
concern with individual products
and processes
Consumer Duty requirements
will be built into BAU monitoring
and management.
Hogan Lovells | 6