Consumer Duty
Practical Consumer Duty support across the four outcomes, fair value assessment, outcome monitoring and the annual board assessment for FCA-regulated firms.
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What We Do
Consumer Duty is not a documentation exercise. PRIN 2A requires firms to act to deliver good outcomes for retail customers, and the FCA assesses firms on the evidence that outcomes are actually being delivered rather than on the quality of the policy that says they should be.
Most firms completed an implementation project. Far fewer can demonstrate, on demand, that their products represent fair value, that communications are understood, that support is accessible at the point of need and that outcome monitoring is granular enough to expose differences between customer groups.
We work with boards and compliance teams to close that gap. That means testing outcomes rather than processes, building management information that supports a defensible board assessment, and remediating where monitoring shows customers are not receiving the outcomes the firm believes it is delivering.
Gap Assessment
We assess current arrangements against the cross-cutting rules and the four outcomes, focused on evidence rather than documentation.
Outcome Testing
We test real customer journeys, files and communications to establish what customers actually experience.
Evidence & MI Design
We design fair value methodology and management information that a board can use to reach a defensible conclusion.
Board Assessment & Remediation
We support the annual assessment and oversee remediation where outcomes fall short.
What's Included
Consumer Duty Gap Assessment
A prioritised assessment against PRIN 2A, the cross-cutting rules and the four outcomes.
Fair Value Assessment Methodology
A repeatable methodology covering price, benefits, distribution chain costs and differential outcomes.
Outcome Testing Programme
Risk-based testing of files, journeys and communications with calibrated scoring.
Management Information Framework
Outcome-focused MI with thresholds, escalation triggers and board-level reporting.
Annual Board Assessment Support
Structure, evidence pack and challenge to support the board assessment and its conclusions.
Remediation Plan
Practical, sequenced actions where monitoring identifies poor outcomes, with follow-up testing.
Who This Service Is For
Firm Types
- - Insurance intermediaries, MGAs and brokers
- - Mortgage brokers, lenders and networks
- - Consumer credit lenders, brokers and collectors
- - Investment, advice and wealth businesses
Situations & Triggers
- - Board assessment evidence would not withstand FCA challenge
- - Fair value assessments rely on assertion rather than analysis
- - Outcome monitoring cannot show differences between customer groups
- - A supervisory request has exposed gaps in the Duty framework
Why Work With Us
Financial Services Only
We operate exclusively within regulated financial services. Every member of our team has direct regulatory experience in this sector.
Senior-Led Delivery
Every engagement is led by a senior consultant with hands-on regulatory experience - not delegated to junior staff.
Practical, Not Theoretical
We build frameworks that work in practice, not just on paper. Our advice is grounded in what regulators actually expect.
Global Reach
We advise across 65+ jurisdictions, combining local regulatory knowledge with a consistent, high-quality approach.
Frequently Asked Questions
PRIN 2A requires firms to act to deliver good outcomes for retail customers. It comprises the consumer principle, three cross-cutting rules covering acting in good faith, avoiding foreseeable harm and enabling customers to pursue their financial objectives, and four outcomes covering products and services, price and value, consumer understanding and consumer support. Firms must monitor outcomes and the board must review an assessment at least annually.
The absence of evidence. Firms can generally describe their intended outcomes but cannot demonstrate them with testing data, particularly on fair value and consumer understanding. Management information that reports activity volumes rather than customer outcomes is the recurring weakness.
A defensible assessment considers total price paid by the customer, including charges applied across the distribution chain, the nature and quality of benefits actually received, differences between customer groups, and whether any group receives materially poorer value. The conclusion must follow from the analysis rather than precede it.
It should set out the outcome monitoring undertaken, the results including areas of poor outcome, the actions taken or planned, an assessment of whether the firm's future business strategy is consistent with the Duty, and a clear conclusion the board can defend. Records should show genuine challenge, not sign-off.
Yes. Where monitoring identifies poor outcomes we help scope the affected population, determine whether redress is required, design the remediation approach, and test that the fix has worked rather than closing the action on delivery.
It can. Firms that can determine or materially influence retail customer outcomes have obligations even where they have no direct customer relationship, which is why distribution chain responsibilities are so important for manufacturers, MGAs and platforms.