Complaints root cause analysis: what the FCA expects from firms
The FCA's root cause analysis report links DISP 1.3.3R to firms' management controls. This guide explains what the FCA found, what good practice looks like, and how to...
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FCA Priority • New Standards for Consumer ProtectionBetter outcomes, fair value and customer understanding.
The FCA's Consumer Duty sets higher standards of consumer protection, requiring firms to put customers' needs first and deliver good outcomes. We help you implement comprehensive frameworks to meet these new requirements.
FEATURED SERVICE
Embed the Consumer Duty and evidence better customer outcomes.
We provide practical, end-to-end support to help you meet the requirements of the Consumer Duty: outcome reviews, fair value assessments, customer understanding and support, outcomes monitoring and your annual board report.
Depends on your starting point
The work follows your products, customers and the evidence you already hold, so we do not quote a standard duration. Monitoring and the annual report then recur.
Evidence that leads to decisions
A proportionate framework should still lead to decisions and remedial action, not a document exercise.
FCA's Consumer Duty focuses on delivering good outcomes across four key areas
Products and services must provide fair value to customers
Communications must enable customers to make informed decisions
Customer service must meet the needs of consumers
Products must meet customer needs and perform as expected
Start with the customer outcome or governance question you need to answer.
Products and services
Check design, target market and distribution fit.
Price and value
Structure fair-value assessment and review.
Consumer understanding
Test communications and customer decisions.
Consumer support
Review support, vulnerability and complaints.
Firms must act to deliver good outcomes for retail customers and avoid foreseeable harm
What to test, what to produce, and how the board sees it.
What the FCA expects, and the evidence behind it.
Outcomes
Define measures and evidence for the four outcomes.
Fair value
Link price, benefits, costs and customer understanding.
Vulnerability
Show support is accessible and responsive.
Governance
Create board-level oversight and remedial action.
Consumer Duty evidence should show what the firm knows about customer outcomes and what it changed.
A board-level view should be based on relevant MI, not only policy attestations.
Comprehensive support to embed Consumer Duty across your organisation. This is how a MEMA engagement runs, not a sequence the FCA publishes.
Comprehensive review of your current practices against Consumer Duty requirements
Practical guidance to embed Consumer Duty principles throughout your firm
Systems to demonstrate compliance and track consumer outcomes
The Duty is assessed on outcomes, which means the firm has to be able to show what its customers actually experienced — not what its policies intended.
In-depth resources to support your Consumer Duty implementation
Detailed breakdown of each outcome, the evidence the FCA expects, and common implementation failures.
GuideWhat PRIN 2A.8 requires, what good looks like, and how to structure your board-level evidence pack.
GuideHow to assess your current position against the Duty's requirements across all four outcomes.
Free ToolFree interactive tool to check your Consumer Duty annual assessment against FCA expectations.
Free ToolStep-by-step self-assessment to identify gaps in your Consumer Duty compliance framework.
In-depth guide
Detailed breakdown of each outcome, what evidence the FCA expects, and the most common implementation failures.
This service is available for firms across these regulated sectors
Compliance support that sits alongside the Consumer Duty.
Common questions about the FCA Consumer Duty
The Consumer Duty (PRIN 2A) requires firms to deliver good outcomes for retail customers. It sets a higher standard of consumer protection by introducing a new Consumer Principle ('a firm must act to deliver good outcomes for retail customers'), cross-cutting rules requiring firms to act in good faith, avoid foreseeable harm, and enable customers to pursue their financial objectives. It represents the most significant shift in FCA conduct regulation since the Treating Customers Fairly initiative.
The Consumer Duty came into force on 31 July 2023 for new and existing products and services that are open to sale or renewal. For closed products and services (those no longer marketed or sold to new customers), the Duty applied from 31 July 2024. All FCA-regulated firms dealing with retail customers must now be fully compliant across both open and closed books.
The four outcomes are: (1) Products and services -- products must be designed to meet the needs of identified target markets; (2) Price and value -- customers must receive fair value, with a reasonable relationship between price and benefit; (3) Consumer understanding -- communications must equip customers to make effective, timely, and properly informed decisions; and (4) Consumer support -- firms must provide support that meets customers' needs throughout the product lifecycle, including making it as easy to switch or cancel as it was to buy.
Yes. PRIN 2A.8 requires firms to produce an annual assessment of how they are delivering good outcomes for customers, which must be reviewed and approved at board level (or equivalent governing body). The first reports were due by 31 July 2024. The report must include evidence of outcomes monitoring, assessment of whether the firm is meeting the Duty's requirements, and actions taken or planned to address any shortcomings identified.
The FCA expects firms to develop a robust Management Information (MI) framework that tracks outcomes across all four areas: products and services, price and value, consumer understanding, and consumer support. Effective monitoring includes regular analysis of complaints data (by root cause), customer satisfaction scores, sales outcomes, attrition rates, and the results of communications testing. MI must be reviewed at board level and should trigger remedial action where poor outcomes are identified.
Yes. Consumer Duty applies to all firms with a role in the manufacture or distribution of products to retail customers, regardless of whether they have a direct relationship with end customers. Manufacturers must share information with distributors to enable them to comply. Distributors must in turn act consistently with the Duty when selecting and distributing products. Both parties must have appropriate agreements in place, and the FCA expects firms to conduct due diligence on their distribution arrangements.
Consumer Duty replaces and significantly strengthens TCF. While TCF set outcomes for firms to demonstrate, the Duty goes further: it imposes a positive obligation to deliver good outcomes (not just avoid bad ones), introduces cross-cutting rules requiring firms to act in good faith and avoid foreseeable harm, and requires firms to enable customers to pursue their financial objectives. Consumer Duty also introduces specific outcome requirements that go beyond TCF principles, requires annual board sign-off on outcome delivery, and explicitly applies across distribution chains.
The firm had completed its initial Consumer Duty mapping but had not proactively monitored whether its ongoing advice fees were delivering fair value in practice across older, closed-book products. FCA data sweeps flagged the firm as a statistical outlier on client charges versus portfolio performance, and it lacked the proactive management information needed to evidence value.
A costed, evidence-backed remediation plan and a proactive fair value evidence base, giving the firm a credible position to put to the FCA.
Get expert support to meet FCA's new consumer protection standards
Phone: 0330 133 0811
Email: contact@memaconsultants.com
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