The FCA’s Consumer Duty requires firms to act in good faith, avoid causing foreseeable harm, and support retail customers in achieving their financial objectives. It demands that firms review and evidence the extent to which they are delivering good outcomes across: products and services, price and value, consumer understanding, and consumer support.
None of this can be achieved without robust data and actionable management information (MI). Why, you ask? Simple. Information fuels decisions, and decisions fuel outcomes.
MI is already an essential component of financial services operations, providing critical insights that informs decision-making and reports that track business performance. And, with the FCA stating that “firm management information” will be a vital tool for measuring Consumer Duty success, it’s never been more important.
By implementing and leveraging quality MI, firms can not only gain a comprehensive view of their diverse customer-base, their products, and their business operations, but they can also drive - and evidence - informed decisions that benefit the customer and fuel good outcomes.
Continue reading to discover data, MI and reporting guidance from Karen Snape, Jaywing’s Analysis Director.
THE BASIS OF MI: DATA
To ensure your firm is collecting relevant data for Consumer Duty, begin by reviewing what your customer experience looks like and map out the data you have and will need to monitor, test and evidence outcomes. For example, identify what data you have around products/services and feature usage, short and long-term value information and trackable online customer behaviours (across websites and mobile apps). The latter is particularly useful as it enables you to understand metrics such as customer response rates to communications which prompt certain actions.
Once you have defined what outcomes you will be measuring (both good and bad), you should be checking:
- What data will you need to capture to measure these outcomes, and at what frequency?
- Are you capturing some of this data already? And, if so, is this existing data being monitored through the lens of Consumer Duty?
Ensuring the data underpinning your MI reporting is fit for purpose will allow you to identify areas where you are producing good outcomes, as well as areas where you may be falling short in meeting the needs of your customers.
For instance, a firm may already be collecting and tracking complaints data, however, this could be monitored with the aim of reviewing overall satisfaction with products, rather than assessing whether there are particular customer groups experiencing worse outcomes. Collecting and visualising the right data will help the business understand why these complaints are arising and what can be done to mitigate the issues and deliver better outcomes.
- Where are the data gaps?
Financial organisations already hold an abundance of data, so it can be daunting to think about capturing more. However, if not all your defined outcomes are currently monitored then enhanced collection will be essential to compliance.
Gaps may be occurring within your existing data, whether that be because the data is not:
- collected at the right frequency
- collected at the right granularity
- sufficiently customer-centric
Financial services data is often collected on a segmented, or aggregated, level rather than at an individual level. An individual customer view is vital to Consumer Duty compliance, particularly where there is a difference in how a good/bad customer outcome is measured for different customer groups.
It is also important to note that you should not just be looking internally for this data. If your organisation is reliant on intermediaries or other third parties, you may need to widen your scope and collect this external information to gain a more comprehensive view of your customers’ experiences. As the FCA remarks, you might want to collect “feedback from other parties in the distribution chain, such as manufacturers and distributors sharing information about the way in which products are sold”.
The type of data you capture will vary depending on the nature and scale of your firm. However, every firm should ensure this data has a robust governance framework, including policies and procedures for data quality, security, privacy, and retention.
THE KEY TO MEANINGFUL MI
Now that you’ve identified what data you need to capture to test your customer outcomes, it’s time to ensure your MI produces actionable information that will allow you to track and improve how you are performing against those outcomes on an ongoing basis.
Crucially, your MI reports should tell you the reasons behind good/bad outcomes. This is essential to meeting the Duty as the FCA expects firms to “spot where customers are getting poor outcomes and understand the root cause” and “be able to demonstrate how they have identified and addressed issues leading to poor outcomes”.
Setting appropriate triggers linked directly to your customer outcomes can track how your firm is performing against Consumer Duty objectives, with an action plan ready to be implemented in the event of any issues. This tracking should contain both descriptive analytics (what has happened) and where possible predictive analytics (what is likely to happen in the future).
By using data visualisation tools, firms can also present data in a clearer and more concise manner, making it easier to identify trends, patterns in behaviour, and “stay abreast of and respond to new or emerging sources of harm”. A good data visualisation tool will also enable users to perform self-serve analysis and interrogate the reports deeper; this should help uncover why shifts have occurred, not just when.
Your MI reports should also reflect who will need to review them (Consumer Duty board member/other stakeholders/regulators) and be customised in order to present the most timely, accurate, and actionable information for these readers. Additionally, as these reports need to be consistent, monitored on an on-going basis, and available to regulators and stakeholders upon request, automation will be necessary. Again, a good data vis platform can really help make this automation less onerous.
The bottom line is: the FCA's Consumer Duty is all about understanding your diverse customer base and doing right by them, and you can't do that without good data and actionable MI.
In fact, the FCA has warned organisations that they can expect to be asked: “What data and management information is the firm using to monitor whether products and services continue to meet the needs of customers and contribute to good consumer outcomes? How regularly is it reviewing this data and what action is being taken as a result?”
With the regulations requiring organisations to continuously assess and improve their operations and outcomes, firms will need to adapt a systematic approach to data management to ensure that MI is good, fit for purpose, and produces actionable insights that are easily monitored. Do this right and you’ll gain compliance, customer loyalty and a competitive advantage, skip these steps and you risk significant penalties and reputational damage.