As part of our series on the Consumer Duty act, we’ve discussed the different aspects of the legislation and explored the impacts and opportunities. But how will firms put this into practice and deliver change to meet the requirements?

The FCA have indicated that businesses should have a high-level plan in place by October 2022. This doesn’t leave a lot of time, so mobilising a core team to solely focus on the changes and implementation should be a priority.

Led by your change management team, key stakeholders from Risk and Compliance teams, operational areas and other key participants in the value chain will need to mobilise rapidly to understand the high-level impacts. A creation of a roadmap to visualise the change journey would be a key objective. This could then be broken down into smaller projects or workstreams to support the delivery.

What is the best approach?

The Consumer Duty will affect firms in different ways, there won’t be a one-size fits all way to proceed. Having a good understanding of the business, how it services clients, and where the largest impacts will be is going to be vitally important at this early stage and should be assessed during mobilisation.

Our SimplifyDNA tool understands the capabilities, services and processes that are likely to be in place within relevant firms and makes the impact assessment and analysis effortless, allowing for rapid completion.

Requirement Gathering

Once the vision and roadmap has been created and agreed firms can then switch their attention to requirements and scope what is required to ensure compliance.

Defining high-level requirements and scoping what may need to change, such as system enhancements, process improvements, document changes or transformation of the business operating model will provide a greater understanding of the impact, estimated timescales and resources required to move into the delivery phase.

Compliance representation will be a key aspect throughout all stages of the change. The high-level requirements can then be reviewed against what is currently in place to identify the gaps between compliance and the As-Is.

There is a risk that a lot of time and resources could be spent on changes that may already be compliant or are deemed lower risk. It is therefore important for compliance to be fully engagement in this analysis stage.

Getting the Detail Right and Moving to delivery

Defining the lower-level requirements will need to be done before any implantation plans are put in place. These will include defining the metrics that will be vitally important to measure the customer outcomes that Consumer Duty requires.

Programmes or projects can then be set up so effective governance can be set up, resources secured, and accountable roles and responsibilities agreed for delivery.

At Simplify Consulting, we can help with all aspects of optimisation; from analysing processes, improving customer journeys to delivering digital and regulatory change and so much more. Get in touch with us today.


Chris Lamb

Wealth Consultant