Customer Outcomes Framework - An example

In our view, the most impactive element of the Consumer Duty for most firms will be the requirement to annually assess whether they are delivering good outcomes for their customers. This is because most firms we engage with do not have a defined set of customer outcomes to measure against. Without this, it is hard to see how your firm can meet the requirements of the Consumer Duty. The FCA (and its predecessor FSA) have had an expectation for firms to have a defined set of customer outcomes ever since the introduction of Treating Customers Fairly (TCF) in 2007. The fact we are seeing the introduction of the Consumer Duty should be taken as a clear sign from FCA that not enough has happened and that firms need to understand the importance of having a customer outcomes assessment framework. This, together with SM&CR and PROD is the most practical way for firms to evidence that they are delivering positive outcomes to a pre-defined target market by design rather than chance.