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Consumer Duty Board Report: Don’t leave it too late
As we set out in our previous article on the subject “Writing your Consumer Duty Board Reports” the deadline for your first report is 31st July this year. However, this does not mean you can’t hold your Board meeting before this deadline, in fact this is a common misconception we’ve come across. Essentially the FCA is not requiring all firms to organise and hold a Board meeting at the end of July, instead the intention behind the rule is that the Board should be provided the report before this date, i.e. at the planned Board meeting date during the first year of the duty.
Understandably many firms may not have been in a position to report on their Consumer Duty progress earlier in the year, perhaps when the Board meeting was planned. In such situations there is nothing to prevent an additional meeting focused on the duty occurring before the 31st July.
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Understanding the reporting requirements, forming the Board report, and developing the discussions at the meeting can be difficult. Firstly, it must be appreciated that building the reporting and forum is something that will evolve over time, as participants become more familiar with the format, purpose, and of course with the duty itself, conversations and data will become more refined.
Stage One: Draft
The first stage is to understand the content required by the FCA. The key elements of the Board report under the duty include a review of the firm’s culture, success at implementing the duty, actions identified from outcomes monitoring and other reviews and an update on those actions. These core elements can then be built on by a review of your firm’s business strategy (looking at how aligned it is with the duty) and input from your consumer duty champion. Overall, the report should effectively communicate your firm's compliance status, strategic priorities, and operational adjustments.
Creating this first report is therefore the output from stage one.
You can short-cut this process by downloading our Board report template which is available on the Consumer Duty resources section of our website.
Stage Two: Consultation
Once you have your draft report, consult with your Consumer Duty champion, the Board and compliance to pool ideas for additional data sets or conversation topics. You may also want to engage with external support, such as consultants, to benchmark against others in your sector.
For this reason, don’t leave it too late before designing your Board report!
Stage 3: Test and Improve
As with everything we do, we learn and improve. Stage 3 can therefore be summarised as ‘go for it’. Once you’ve consulted and the report is in the best shape possible, when you step back and look at it, if you’re convinced it is giving the Board a genuine picture of the outcomes received by customers as well as the firm’s progress on duty compliance, then simply go for it – often the areas for improvement don’t come out until you actually run the review.
By following these guidelines, your Board report will not only meet regulatory expectations but will also drive meaningful discussions and decisions that enhance consumer outcomes and align with the overarching principles of the Consumer Duty.
Our full range of Consumer Duty compliance resources – including webinars and downloadable content such as our template Board Report – are available to browse and buy here: Consumer Duty Compliance Resources | RB Compliance Consultancy
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