The Training Environment For Financial Services

Compliance Monitoring - the impact of the Consumer Duty


Course Outline & Objectives

The Consumer Duty formally imposes an actionable duty on regulated firms to deliver good outcomes for retail customers with a focus on products and services, price and value, consumer understanding and consumer support. These build on previous FCA initiatives such as Treating Customers Fairly and the Conduct Risk Framework. 

The Duty is inextricably linked to these non-rules-based obligations which rely on subjective tests of “fairness” rather than objective legal tests. This means compliance will always be subjected to a test of hindsight if the FCA decides to take action.


This practical course provides a safe environment in which to look at your approach to assessing the impact of the Consumer Duty on your monitoring activities and the underlying risk assessment so that your firm and its management can be confident that the monitoring is providing a true picture of the Consumer Duty risk within your firm, using a number of examples with delegate input.


Attending will help you:

  • Understand what the Consumer Duty expects firms to deliver and the pitfalls it creates
  • How this affects risk assessments and management information, the changes you may need to consider while minimising bureaucracy
  • How to create or identify auditable Consumer Duty outcomes that are relevant for your firm, ensuring this is embedded within the strategic plan and linked to your firm's culture and values
  • The conclusions your monitoring needs to draw which will provide an evidential basis for any assessment of the extent of compliance/non-compliance. The balanced scorecard.
  • What techniques might be most helpful - identifying which monitoring techniques will be most appropriate a resource-constrained environment
  • Leveraging existing information/monitoring infrastructure - the importance of not reinventing the wheel - if existing business MI can be repurposed for the Consumer Duty monitoring, then it will be more useful to the business

Who will benefit?

This focused course will be of value to anyone responsible for risk assessment, creating or implementing monitoring programmes. This is likely to include Senior Management Team, as well as heads of Risk, Compliance and Audit, and individuals who compile reports for the senior management team.


Training Approach

This course will comprise a blend of trainer presentation, group discussions, exercises and examples. There will be ample opportunity for questions, experience sharing and networking. All course documents, (as well as refreshments and lunch for face-to-face courses) will be provided.



Course Presenter

Gary Pitts has over 25 years of compliance experience in the UK and overseas, including spells in regulation, asset management, investment banking and as managing partner of a boutique financial services house. A FSA/FCA registered person in Controlled Functions 10 and/or 11 since 2001, he now runs his own governance and regulatory consultancy: Tetractys Partners LLP. Gary is a regular conference speaker and author of technical articles on compliance related topics and sits on the regulatory advisory group of the Journal of Securities Operations and Custody. He brings a combination of compliance and commercial experience, in terms of both practical implementation and Board level oversight, to the training he delivers.


Course Programme


Session Content
What the Consumer Duty expects firms to deliver
  • What is the Duty?
  • What might trigger a “breach” of the Duty leading to discipline?
  • What might that look like to us?
  • The importance of robust ownership and governance
  • How this links to monitoring
How this affects risk assessment and mi
  • The key questions you need to ask yourselves
  • Defining good outcomes for customers in the context of the strategic plan and the evidence of governance
  • Would our customers agree with this definition?
  • How this links to risk, controls and metrics
  • Embedding the Consumer Duty MI in the Board's commercial discussions
Creating relevant auditable outcomes for your firm
  • How risks, mapped to impact on outcomes can identify appropriate controls and measurable metrics
  • Identifying the contribution of all areas of the business to “good outcomes” and drawing auditable outcomes out from this.
The conclusions you need to draw
  • What has the FCA said previously about the questions firms should ask themselves?
  • What does this imply for the conclusions we need to evidence from Consumer Duty monitoring?
  • What might these look like (worked example)
  • Developing a balanced scorecard
Helpful techniques
  • TCF
  • Conduct Risk – how to make the mapping work effectively
  • Risk assessment identifying relevant MI which can form the basis for a desk-based monitoring approach
  • Contributions of Risk and Internal Audit
Leveraging existing monitoring / infrastructure
  • Link TCF and Consumer Duty outcomes
  • What can our Conduct Risk mapping tell us?
  • How can we leverage the PROD process and product stress testing
  • Vulnerable customers processes and what they contribute
  • The policy ecosystem


This course can be delivered in-house at a time and location to suit your business and tailored to suit your people and organisation. We can also create bespoke training when something very specific is needed.Please contact us to discuss your requirements in more detail and at no obligation.

Bottom Banner
© 2014 Corporate Training Partnerships. All Rights Reserved. Terms and Conditions | Privacy Policy