Firms will be expected to be able to demonstrate that they continue to meet the Consumer Duty requirements and can meet the cross rules and four outcomes (Price and Value, Products and Services, Client Understanding and Client Service). There will also need to be an annual report to the Board setting out how the firm is meeting the expectations of the FCA.

CATS can help you do this by conducting an annual audit specific to the Consumer Duty. This will include:

• A review of the firm’s culture and governance
• Management Information specific to the Consumer Duty
• A review of the firm’s latest Value Assessment and evidence that supports this.
• Checking at what evidence the firm has to demonstrate client understanding.
• Reviewing how the firm manages behavioural biases.