Maddie Delboy, Head of Regulatory Support, looks at how PROD interacts with Consumer Duty and what else the regulator is looking for in the Consumer Duty rules.
One of the first reactions to Consumer Duty was as ‘TCF on steroids’ and then as we went through rounds of consultation, this eventually morphed into ‘PROD on steroids’. Sometimes I see the mass of articles, webinars, seminars and all things in between regarding Consumer Duty and I think the sight of ‘what is consumer duty’ has been lost, so that makes it hard to look at the how.
Just as a recap (which you can skip if you have seen it too much…) Consumer Duty is all about a shift to outcomes-based regulation and a mandated focus that the client is at the centre of all regulated businesses. The regulator wants firms to put themselves in the client’s shoes at every single touch point along the financial services journey. Those touch points have been highlighted as ‘the four outcomes’.