In Focus: Consumer duty 1 year on  

'I'd be worried if data came out as a theme in closed-book consumer duty'

The first phase has been "a big change project", he says. "Because even if you don't make any changes to a product, the function of reviewing that whole journey is a big piece of work.

"So it's a big change project to review all those journeys across all of your products for all of your customers and, you know, the more complex your business, I guess the wider that piece of work is."

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He adds that consumer duty has broadened the thinking across the value chain, prompting advisers to consider their own charges as well as those of products and functions they might not need.

"Advisers are now asking for more sort of segmented client data from providers to say tell us a bit more about who we have and how things are performing and obviously been asking us for evidence of the assessment of value work that was done first time around – and again, they want to know and review those sorts of things with products again this time around," he says.

"Advisers are simply more data hungry than perhaps they were before, because they know they've got to fulfil their own duties."

He adds: "I think it's a good exercise because if you combine that with all the data requirements on the dashboard, for pensions, particularly, you think those things go hand in hand quite nicely, reviewing the product and its suitability and its sort of competitiveness, but also making sure the data is up to date.

"It feels like it will help move the industry forward and increase trust. And that's got to be a good thing. So a big exercise, but worth it."

carmen.reichman@ft.com