With the FCA keen to review a ‘broad sample’ of Consumer Duty board reports from July, firms should expect the FCA to closely scrutinise what and how you are reporting the Consumer Duty-mandated improvements in your culture. For some firms, evidencing a culture shift to deliver the best outcomes for their customers will be simple; for others, it will be a minefield, setting off alerts that will attract unwanted attention from the regulator.

The key takeaways from this insight paper are:

• The Consumer Duty Board Report should tell a compelling story about your firm’s culture. Firms should see the new report as an opportunity to demonstrate commitment to delivering great service to consumers.
• Traditional metrics may not capture the true behaviour patterns in a firm, or true outcomes for consumers. firms should consider alternative data sources that can provide a more accurate representation.
• Be aware of factors and patterns that the regulator ‘red flags’, such as an unwillingness to have difficult conversations or ignoring bad news. These indicate a failure to truly understand and engage with the Consumer Duty requirements.
• Leading firms are embracing Consumer Duty, using it as an opportunity to align their commercial objectives with its requirements. This approach has a positive impact on their culture and customer service.
• To implement Consumer Duty properly requires evidence, transparency, and effective communication.
• A customer-centric culture is now mandatory – not a ‘nice-to-have’.