Consumer Duty Board Reports: Examples of Good and Poor Practices

• Clear processes for production of the report: Some reports were clearly created over a long enough period to involve relevant business areas, forums, and committees in the process, e.g. included departmental updates in their analysis.
• Challenge from the Board: Reports mentioned Board challenges either within the report or in related meeting minutes, e.g. submissions included Board requests for additional information to show compliance with the four outcomes, such as details on target markets and user research testing.

• Business input into production of the report: In some cases, reports were mainly produced by Compliance or Consumer Duty teams, which increases the risk to miss input from key experts and reduce business ownership of identified issues.

• Good quality data: Firms used a mix of quantitative and qualitative data gathered from both internal and external sources, e.g. include data on complaints
• Analysis of different customer types: Reports considered various customer groups, including those with vulnerable characteristics, e.g. Some firms showed how they identified vulnerable customers by using specialist teams with the TEXAS (Think, Explain, eXplicit consent, Ask, Signpost) model.
• Comprehensive view across distribution chains: Some reports clearly outlined third-party relationships and the processes for sharing information across the distribution chain, e.g. a firm developed a Distribution Feedback Template to share its sales data.

• Some reports lacked clear definitions of good outcomes for products and services.
• Many reports missed specific Management Information (‘MI’) thresholds and used vague claims instead.
• Where thresholds and RAG ratings were mentioned, justifications were often weak.

E.g. Some firms briefly mentioned their data sources but lacked a balance between qualitative and quantitative metrics. One firm mentioned investor feedback analysis but didn’t outline further actions or future plans.

• Taking effective action: Good reports included examples to show actions taken to address risks and evaluated their effectiveness, e.g. firms provided examples where products/services were removed from sale after assessments showed they didn’t meet customer needs.
• Consumer Support: Some reports detailed the firm’s efforts to support consumers, e.g. training frontline staff who have direct interface with customers.
• Consumer Understanding: Good reports showed how consumer understanding obligations were met by including results of actions taken throughout the year, e.g. a report showed a comparison of communication changes after using its new framework.

• Taking effective action: Some reports identified issues without showing a clear plan for resolution, while others claimed actions were taken but lacked evidence of their effectiveness.
• Analysis of different customer types: Poor reports did not assure the Board that actions were taken to address issues for vulnerable consumers, e.g. in one case, a large firm briefly mentioned vulnerability but didn’t show any real changes from its new approach.

• Focus on culture throughout the firm: Reports mentioned initiatives aimed at embedding the Duty into the firm’s culture, e.g. reports showed data on staff completion of Duty-related and vulnerability-specific training.
• Products and Services: Firms often mentioned their product governance changes since the Duty’s introduction, explaining how these would help achieve better outcomes, e.g. charts used to analyse how new committees aligned with the four Duty outcomes fit into existing structures.

• Strategic Change: Reports often claimed their strategy aligned with the Duty but lacked details on any review or necessary changes.
• Taking effective action: Poor reports mentioned future actions but lacked a clear plan to address the identified issues, e.g. some actions had no clear owners or timelines, that increases the risk of inaction and poor customer outcomes.