New Consumer Duty regulation will give firms an opportunity to take ownership of data-driven innovation. The FCA will be pressing to understand how firms are achieving
good consumer outcomes. They will look at management information and try to understand how senior leaders in these firms are challenging that the right outcomes are being delivered for customers. The regulator will try to see if firms are using all the data and information available to them to ensure that they are delivering these outcomes.
The FCA is not expecting Consumer Duty to be a regulation that only sits in compliance. It’s keen that it promotes a culture that permeates throughout and at all levels of the organisation. One of the Duty’s requirements is for firms to appoint a Consumer Duty champion. For smaller firms without a board, it should be someone who has a broad responsibility across the organisation. While smaller firms may not be expected to provide the same amount of data as bigger ones, there should be proportionality with how they deal with the different stages of the process and across the organisation.