Move fast and miss nothing
Quickly find gaps in compliance and prioritise remedial work
Be ready to provide the FCA full proof of compliance, "Show them, don't tell them"
Bring all supporting evidence together in one place
Use CD Control Room with your implementation plan and for ongoing compliance
What our clients have to say
Andy Hunt, Head of Risk and Policy,
Wren Sterling
It is a real pleasure to work with a team that has such a deep understanding of our industry and the challenges we face.
Helen Vaughan, COO,
J O Hambro Capital Management
Very easy to work with, helping us to solve complex regulatory challenges with practical solutions.
The Four Tests
We developed the Four Tests so that they can be applied to the Consumer Duty Outcomes. We have taken this approach because the outcomes are tangible and specific and are the lens through which the FCA will assess a firm’s implementation plans and ongoing compliance.
Each test is applied through a workflow with a set of carefully designed questions that progressively reveal areas of compliance or non-compliance. We have built and refined this approach through working with firms on their Consumer Duty implementation plans.
Test 1: Customer profiling
Is your customer profiling granular enough to allow you to deliver effectively across the four outcomes? Is there a clear connect between your knowledge of your target customers and the way that you build, sell and support your products and services? How well do you understand the characteristics, needs, objectives and expectations of your customers? This is the foundation of the Consumer Duty regulation.
Test 2: Distribution chain analysis
Do you have the big picture that allows you to be sure that the end to end distribution chain of which you are part delivers good outcomes for retail customers. Is this documented across all four outcomes? You are not responsible for the performance of other businesses in the chain but you should be able to demonstrate that you understand the overall chain and how it delivers to the retail customer.
Test 3: Process documentation
Well documented processes are simply the best way of capturing and communicating how you do things across all four outcomes. Whether it’s a product design or customer support process, clear documentation drives efficiency and collaboration and allows you to easily demonstrate to the FCA that you are in control. A process led approach gives a single view of how things are done, avoiding gaps and fragmentation.
Test 4: Monitoring and accountability
This test looks at how you measure the performance of working processes across all outcomes and update and refine those processes to ensure that your products and/or services continue to meet the needs, characteristics and objectives of your target market. Clear individual accountability is also important here, where there also needs to be a link back into the Senior Managers and Certification Regime (SMCR).
CD Control Room in action
London based asset management firm using CD Control Room to test their Consumer Duty implementation plans.
The tests showed that the firm had developed a very comprehensive Consumer Duty implementation plan across all four outcomes but had not created much in the way of process documentation as evidence.
The priority action was to create high level process documentation that evidenced the firm's approach to complying with the Consumer Duty across all four outcomes.