Only 1 per cent of firms say their annual board report to confirm they are complying with consumer duty has been completed and signed off.
A poll of 656 financial services professionals, carried out by Square 4 in partnership with AI provider Elephants Don’t Forget, found 16 per cent of respondents had not started or allocated ownership for drafting the report.
One of the elements of the consumer duty is the annual requirement for a firm’s board to review and approve the firm’s report on retail customer outcomes, confirm the firm is complying with its consumer duty obligations, and that its business strategy is consistent with consumer duty principles.
Firms should expect the FCA to scrutinise the report and, in some cases, request the underlying evidence to support conclusions and actions being taken.
The deadline for the report to be signed off is July 31 2024 however only 13 per cent of respondents said they had conducted a “dry run”.
When asked whether the board report would be able to demonstrate compliance with principle 12 of the duty, 64 per cent said yes, 1 per cent said no and 35 per cent stated they were not sure.
In a webinar looking at the results of the poll, Adrian Harvey, chief executive of Elephants Don’t Forget explained how firms can proactively demonstrate an authentic approach to aligning with the FCA’s narrative around continual assessment and improvement practices.
He said: “We frequently get asked: ‘how can you help us to demonstrate that we’ve got a more appropriate consumer duty culture in this organisation?’
“One of the things we point to is this ‘single-point-in-time’ training mechanic that a lot of firms are involved in; where they train somebody and then the training is not revisited for 12 months and when it is, it’s a refresher training which is probably exactly what was delivered 12 months previously.
“Culturally, this approach does not point to an organisation that is embracing putting the customer at the centre of their organisation; when they are simply ticking a box to say their people have been trained, now ‘get on with the job’. This approach couldn’t be further from the authenticity that the regulator has in mind.
“That’s why firms are asking for help and assistance in terms of: ‘how can we do this more authentically, how can we change our culture?’ For us, it’s by ensuring your people genuinely know what they are doing and that comes down to individual employee competence.”
Matthew Drage, managing director at Square 4 and former supervisor at the FCA, reiterated the need for continuous progression and to remind firms of the risks of being complacent with requirements.
“One of the risks with board reporting is that you can do a fantastic board report, but it sits on the ‘imaginary shelf’ for 12 months, gathers dust, and is then revisited in May, June or July again the following year.
