Does Our Governance Ensure Good Outcomes for All?
The problem:
Since SM&CR, expectations for transparent and effective governance have increased. The Consumer Duty further emphasises firms and SMFs evidencing oversight and control, especially around avoiding “foreseeable harm.”
In the words of FCA Consumer Duty Manager, Richard Wilson: “Simply put, we want to see products and services designed to meet the needs of a clearly defined target market and then we want firms to monitor and see what happens in practice”
Firms must design products and services for a defined target market and monitor outcomes. If issues arise, SMFs must show the “reasonable steps” they took to prevent foreseeable harm. This always looks so much clearer with the benefit of hindsight which is what the regulator will have the luxury of, if/when something was to go wrong.
A targeted proposition makes areas of potential harm easier to identify, which then needs to be supported by a culture & mindset of continuous improvement and meaningful management information.
Conduct Culture can help firms like yours demonstrate robust governance, oversight and control to meet rising expectations - especially around target market suitability and avoiding foreseeable harm.
By engaging us, we can work with you to answer:
Are the right governance structures in place, adequately informed and driving the business to deliver good outcomes for all stakeholders?
Ensure you are outcomes focused
Engage external subject matter (marketing) specialists to help identify, understand and document the needs of your ideal target market
We advocate the use of an outcomes focused governance model as, when done correctly it brings simplicity, clarity and focus whilst effectively addressing the information needs of both the accountable SMFs and the wider stakeholders (including Directors, Shareholders, Colleagues and Regulators). An outcome focused governance model, should help firms in meeting the FCA expectation “to collect enough information to be able to act to avoid causing foreseeable harm.”
We have created an example Customer Outcomes Framework that you can start using today. Click here to get your copy
Interested in addressing the pressure points in your business?
“Exceed expectations. The team at Conduct Culture were accessible and responsive throughout the project. They took the time to understand our business and what we were aiming to achieve and delivered proactive and practical solutions which met the interests of all parties involved and enabled us to advance our review.”
Andy Pennie
Intelligent Pensions
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