Our services - Consumer duty
Consumer duty advice & implementation support
We can provide project support to ensure that your implementation plan is implemented. We can provide on-site end-to-end project management support or on a support basis to your existing team.
Compliance audits and policy writing
We can provide recommendations following our audit into the relevancy and effectiveness of your compliance arrangements against the new consumer duty requirements. We can also help write your policy and procedural documents.
We can provide training to your teams on a bespoke basis to help them as part of their roles and responsibilities. Our training can be delivered and tailored to boards, senior management and departments, both online and face-to-face.
Policy and Procedure Review
We can review your firm's existing policies and procedures to ensure they align with the Consumer Duty principles. We can help develop new policies and procedures to promote fair treatment and better outcomes for consumers.
We can assist in developing a tailored implementation plan that outlines the necessary steps and actions to ensure compliance with the Consumer Duty. This can include setting objectives, defining timelines, and allocating resources effectively.
We can offer independent reviews of your firm's adherence to the Consumer Duty requirements, providing an objective assessment of your practices and recommendations for improvement.
We can review your complaint handling root causes, policies and processes against the consumer duty requirements and provide recommendations, as well as create your key policies.
We can help ensure that your policies and procedures are adequate and that vulnerable customers are receiving good outcomes and are being treated fairly throughout the customer journey.
How we will support you
We spend time understand your business, people, culture and business requirements.
We prepare a business proposal, including a plan of action, based on your unique needs.
We provide initial and ongoing support to deliver your requirements. This can also entail onsite and in-house support.
Recent work we have completed
We helped an insurance group implement the consumer duty as well as support them across their vulnerable customer strategy, call handling and training.
Assessing whether our insurance client's current products and services and support were delivering good customer outcomes, particularly for vulnerable customers.
Scope of our work
1. End-to-end project management.
2. Project planning.
3. Assessment of existing communication channels and their effectiveness.
3. Gap analysis across communication channels, testing different scenarios.
4. Implementation of changes and recommendations.
1. Product development for target customer groups, including customers with vulnerable characteristics.
2. Improved the support channels available for target customer groups, including customers with vulnerable characteristics.
3. Provided ongoing monitoring in assessing effectiveness of implemented measures.
4. Reduced no. of complaints overall.
5. Implemented changes following focus groups and customer feedback from research in assessing effectiveness of measures.
We helped a lender and credit broking firm improve its remuneration and bonus structure in managing its conducts risk and achieving good customer outcomes.
We carried out a gap analysis review on behalf of a lender and credit broker to assess whether their remuneration and staff incentivisation policy was leading to good customer outcomes.
1. Project planning: defining cost, schedule and cost.
2. Defined existing remuneration and bonus structure; understood how products were being sold; understood pricing.
3. Gap analysis across remuneration, bonuses and staff incentivisation.
4. Implemented changes across remuneration structure.
5. Provided training to senior management and frontline staff.
Outcomes we delivered
1. Changed the firm's renumeration and bonus structure, enabling them to deliver good customer outcomes and managing conduct risk more effectively.
2. Lowered customer complaints, especially relating to post-sale support.
We helped a banking client meet their regulatory obligations across customer support and communication
We project managed and provided support to our client in helping them assess whether their customer support and communication processes were adequate and effective in delivering good customer outcomes.
1. End-to-end project management.
2. Project plan: defined resources, schedule and budget.
3. Defined existing communication channels.
3. Conducted gap analysis across the firm's communication channels including testing different scenarios.
4. Implemented changes across the firm's communication structure and channels.
5. Carried out testing and ongoing monitoring.
Outcomes we delivered
1. Improvement of client communication to its customers.
2. Implementation of additional communication channels.
3. Delivery of effective communication and customer support for customers with vulnerable characteristics.
4. Improvement of customer support both pre and post-sale of services.
The new Consumer Duty
What is the Consumer Duty?
The FCA's Consumer Duty sets to raise standards for consumers. It consists of the following:
The cornerstone of the Consumer Duty rules is Principle 12, which mandates that firms act in the best interests of retail customers. This fundamental principle requires firms to proactively take measures to ensure positive outcomes for their customers.
Cross Cutting Rules
To support firms in understanding and implementing Principle 12 effectively, the FCA has established a set of cross-cutting rules. These rules offer practical guidance and provide clarity on the FCA's expectations, enabling firms to align their practices accordingly.
The Four Outcomes
The Consumer Duty rules outline four key outcomes that firms should strive to achieve in their interactions with retail customers:
Outcome 1: Products and Services - Firms must offer high-quality products and services that meet the specific needs and expectations of their customers. This outcome emphasises the importance of delivering value and ensuring customer satisfaction.
Outcome 2: Price and Value - Firms must provide fair pricing and offer products and services that deliver reasonable value to customers. Transparency in pricing and promoting competitive deals are essential to achieve this outcome.
Outcome 3: Communications and Customer Understanding - Firms must ensure that customers have access to clear, concise, and understandable information about the products and services they engage with. Enhancing customer comprehension and facilitating informed decision-making are key objectives of this outcome.
Outcome 4: Customer Support and Service - Firms must establish robust customer support mechanisms, promptly addressing customer needs and providing adequate assistance throughout their journey. Effective complaint handling and responsive customer service are critical elements of this outcome.
Customer Journey Focus
The Consumer Duty rules emphasize that firms should consider the needs, characteristics, and objectives of their customers at every stage of the customer journey. This inclusive approach promotes fair treatment and acknowledges the varying vulnerabilities customers may face.
Monitoring and Accountability
Firms are required to actively monitor customer outcomes and gather evidence to demonstrate that positive outcomes are being achieved. This promotes transparency, accountability, and continuous improvement in customer service practices.
Consumer Duty - What the FCA expects from firms
The FCA expects that firms:
put consumers at the heart of their business and focus on delivering good outcomes for customers
provide products and services that are designed to meet customers’ needs, that they know provide fair value, that help customers achieve their financial objectives and which do not cause them harm
communicate and engage with customers so that they can make effective, timely and properly informed decisions about financial products and services and can take responsibility for their actions and decisions
not seek to exploit customers’ behavioural biases, lack of knowledge or characteristics of vulnerability
support their customers in realising the benefits of the products and services they buy and acting in their interests without unreasonable barriers
consistently consider the needs of their customers, and how they behave, at every stage of the product/service life-cycle
continuously learn from their growing focus and awareness of real customer outcomes
ensure that the interests of their customers are central to their culture and purpose and embedded throughout the organisation
monitor and regularly review the outcomes that their customers are experiencing in practice and take action to address any risks to good customer outcomes
ensure that their board or equivalent governing body takes full responsibility for ensuring that the consumer duty is properly embedded within the firm, and senior managers are accountable for the outcomes their customers are experiencing, in line with their accountability under the Senior Managers and Certification Regime (SM&CR)
Raising standards and delivering good consumer outcomes
The introduction of the Consumer Duty by the Financial Conduct Authority (FCA) represents a significant milestone in the realm of customer protection.
1. Placing Customers at the Core
The Consumer Duty fundamentally shifts the focus of firms towards prioritising customer welfare. By mandating firms to act in the best interests of retail customers, the Consumer Duty reinforces the notion that customers' needs and interests should be at the heart of all business decisions. This commitment to customer-centricity sets a higher standard of care and protection.
2. Proactive Measures for Positive Outcomes
The Consumer Duty requires firms to take proactive measures to ensure positive customer outcomes. It goes beyond mere compliance with regulations and demands that firms go the extra mile to deliver products and services that genuinely meet customer needs. This commitment to proactive action raises the standard for customer protection, creating an environment where customer well-being is actively promoted.
3. Transparency and Fairness
The Consumer Duty emphasises the importance of transparent and fair practices in customer interactions. Firms are required to communicate clearly and honestly, providing customers with the information they need to make informed decisions. This emphasis on transparency and fairness ensures that customers are empowered and protected from misleading or deceptive practices.
4. Tailored Support for Vulnerable Customers
One of the crucial aspects of the Consumer Duty is the recognition and support for vulnerable customers. Firms are obligated to consider the unique needs and circumstances of vulnerable customers, ensuring they are not disadvantaged or exploited. This commitment to inclusive practices sets a higher standard for customer protection by promoting fairness, empathy, and equal treatment for all customers.
5. Monitoring and Accountability
To ensure adherence to the Consumer Duty, firms are required to establish robust monitoring and accountability mechanisms. Regular monitoring allows firms to track customer outcomes and identify areas for improvement. By holding firms accountable for their actions, the Consumer Duty reinforces the commitment to customer protection and incentivises firms to continuously strive for excellence.
6. Driving Culture Change
Beyond regulatory compliance, the Consumer Duty aims to drive a cultural shift within firms. It promotes a customer-centric culture where firms prioritise customer interests, foster ethical conduct, and embed a strong sense of responsibility towards customers. This cultural transformation sets a higher standard for customer protection by embedding customer-centricity as a core value.
One of the primary challenges for firms is the need for a cultural transformation. Shifting towards a customer-centric culture requires a fundamental change in mindset, practices, and processes within the organisation.
Enhanced Compliance Requirements
The Consumer Duty introduces new compliance requirements that firms must meet. This includes a deeper understanding of the regulatory framework, ensuring robust systems for monitoring customer outcomes, and demonstrating evidence of compliance.
Tailoring Products and Services
Firms must tailor their products and services to meet the diverse needs of retail customers. This requires a deep understanding of customer segments, conducting thorough market research, and implementing product development strategies that prioritize customer outcomes. Adapting existing offerings or creating new ones may pose challenges in terms of resources, expertise, and time.
Communication and Transparency
The Consumer Duty places a significant emphasis on clear and transparent communication with customers. Firms need to ensure that their communication strategies, including marketing materials, product disclosures, and customer interactions, provide accurate and easily understandable information. Maintaining transparency while complying with regulatory requirements can be a delicate balance that firms need to navigate.
Support for Vulnerable Customers:
Meeting the needs of vulnerable customers presents a unique challenge for firms. Firms must develop strategies and processes to identify and provide appropriate support to vulnerable customers, ensuring their financial well-being and protecting them from potential harm. This may involve training staff, implementing additional safeguards, and offering tailored services to cater to the specific needs of vulnerable customers.
Sectors we serve
We work with start-ups to unicorns and offer bespoke support across licence authorisation, compliance and support across the UK and Europe.
We help retail, private and investment banks with authorisation applications, PRA & FCA compliance, financial crime and training.
We help firms with FCA authorisation applications, compliance support, training and related services to help them meet regulatory obligations.
We provide comprehensive assistance to general insurers and Lloyd's of London brokers across compliance, training and authorisation.
From buy now pay later to traditional lending models, we advise firms on operations, compliance, training, strategy, authorisation, and ongoing regulatory requirements.
We work with start-ups to established firms in helping with Electronic Money Institution licence authorisation applications, compliance, training, policy and more.
We help clients with regulatory licence authorisation applications as well as governance, risk and compliance, across a number of countries.
We work with UK and European regulators and can help you become authorised to offer investment services as a regulated business.
We offer a range of services including compliance, training, and authorisation support, specifically tailored for mortgage providers and brokers.
We help open banking firms, including account information service and payment initiation service providers, across compliance, training, authorisation and regulatory support.
Our insights on the new Consumer Duty
Why leading firms choose us as their partner.
"We engaged Buckingham Capital Consulting to support us in implementing the FCA's Consumer Duty requirements and improve our service delivery to customers. Their expertise and approach have been instrumental in guiding us through a gap analysis, developing an implementation plan, and enhancing our practices.
Buckingham Capital Consulting conducted a thorough gap analysis, assessing our current processes and identifying areas where we could further align with the Consumer Duty outcomes. Their in-depth understanding of the regulatory requirements enabled them to provide actionable insights and recommendations to enhance our approach to products and services, pricing and value, consumer understanding, and consumer support.
With their guidance, we developed a tailored implementation plan that addressed the identified gaps and aligned our operations with the FCA's expectations. Buckingham Capital Consulting's expertise allowed us to enhance our customer experience.
Throughout the process, their team provided ongoing support, ensuring effective implementation of the plan and monitoring our progress.. Their collaborative approach and industry knowledge have helped us to deliver a better service, putting our customers at the forefront of our operations."