Implementing the FCA Consumer Duty (Tier 1 Bank)

Summary

Facing a critical industry-wide regulatory shift, a Tier 1 Retail Bank needed to rapidly mobilise specialised expertise. The FCA's new Consumer Duty represented a seismic conduct and compliance overhaul - one that required meticulous product reviews and enhancements across the bank's portfolios. With tight deadlines looming, they needed a partner who could hit the ground running with the right resources and deep domain knowledge. How could they ensure compliance while minimising disruption? Read more to find out how we achieved this.

The Challenge 

Navigating complex regulatory landscapes requires expertise and agility. In September 2022, one of our longstanding Tier 1 Retail Bank clients approached us with an urgent need for specialised resources to support their implementation of the FCA Consumer Duty regulation – a critical industry-wide conduct and regulatory initiative.

As a trusted partner with a proven track record of delivering business-critical programmes, Adams + Oliver was well-positioned to address this challenge. Our deep expertise in regulatory compliance and extensive network of top talent ensured we could provide the right resources to drive success.

Our Response

Time was of the essence, and we moved swiftly to propose a solution. Within two weeks, we presented a team of twenty highly qualified associates, perfectly suited to tackle this endeavour. We were honoured to be chosen as the sole provider for this crucial project.

Since then, we have strategically phased in additional expert resources to build capacity, ensuring our client has the support needed to navigate this complex undertaking. Our associates have taken on vital roles, working across product review and business-as-usual workstreams, including stepping in for senior client managers redeployed to other areas.

The Outcome

Adams + Oliver associates are now leading product and service review activities through workshops and comprehensive reporting. Their responsibilities include:

• Understanding and reviewing the core purpose of each product and its features.
• Assessing all impacts on customers.
• Evaluating the appropriateness of the current target market.
• Assessing whether products are delivering positive customer outcomes.
• Conducting price and fair value assessments.

The ultimate goals are twofold:

1. Produce detailed reports and obtain necessary data for the bank and FCA, identifying whether products meet Consumer Duty requirements or require remediation.
2. Assess the impact of any necessary repairs, allowing the bank to prioritise efforts and, in some cases, leverage Adams + Oliver's expertise to implement enhancements directly.