“There has to be governance around this and there has to be continuous checking to make sure those actions are progressing throughout the year. Reporting back through governance committees within the organisation to evidence this is absolutely key, it can’t just be a yearly exercise,” he added.
During the webinar the panel was asked if the board report needs to reflect FCA engagement pieces and understanding of expectations.
Darren Fisher, advisory director at Square 4 emphasised there was a need to align consumer duty with specific FCA engagement.
He explained: “It's less about the general consumer duty publications from the FCA and probably more about referencing specific FCA engagements you’ve had.
"For example, I’ve been working with a firm recently who are drafting their board report, painting that ‘rosy round the door’ picture a sea of green but we already know they are going through enforcement and a 166 for their poor collections practices, so there is a complete disconnect there.”
alina.khan@ft.com
