Embedding consumer duty in an investment technology firm

Our customer is an Investment Technology firm offering client propositions for savings, pensions and stocks & shares.

There had been two previous attempts to implement and embed a key regulatory programme resulted in technical compliance of Consumer Duty, but without the expected controls, laboured processes and a lack of general understanding from colleagues as to their responsibilities. This led to audit finding and Board Misalignments that required closure.

The third iteration of the implementation was approved, with a focus on completing the shift and embedding Consumer Duty in everyday ways of working. The need had been clarified to include technical, process and cultural requirements. The first 6 months of a 12-month period focused on mobilisation only, without clear deliverables and accountabilities.

Senior leadership recognised the lack of progress and looked to assign stronger leadership across the business and change communities.

A new Business Owner from the Compliance function was assigned to oversee the overall success of the programme. Project One were engaged to provide Programme Management capability to define and plan five separate workstreams. Following a series of strategic planning sessions, with five workstream leads appointed to support execution, the revised plan was agreed for implementation and the Programme moved back to Green. The workstreams were Consumer Duty framework (policy refinement and colleague training), People & Culture, Client Communications, Vulnerable Clients and Management Information.

Each workstream was led by a differing part of the business. The Management Information workstream required enhancements to multiple reports to reflect the number of vulnerable clients impacted and served by the business, this is to ensure Clients with vulnerabilities are not treated adversely. The reporting architecture was under transition and the workstream required intensive analysis to understand the most pragmatic and practical method to provide the data to Senior Leadership to support decision making. Several prioritisation sessions were required with commitment to delivering tactical solutions where necessary.

As Consumer Duty cuts across all teams and colleagues, one of the major challenges was defining and agreeing a training rollout plan that minimised the impact to BAU activities, but achieved the core requirement to embed the Duty in day-to-day work. The team created an innovative training module that blended expert-led training with engagement and team work. This was scheduled and run on a team basis, with ~2000 colleagues trained in a 3-month period. The results were outstanding, with >99% showing an enhanced knowledge of the Consumer Duty and how it applied to their role.

The final challenge was agreeing the BAU model to maintain compliance with Duty regulation at a point where the organisation was changing ownership.  Recruitment was required through the Summer and a contingency arrangement was required to ensure that there was coverage for daily queries and analysis. This was formally approved and a transition date set.

All five workstreams achieved their objectives and the planned audit issues and board misalignments were closed. All colleagues were trained in Consumer Duty and a forward plan for continued learning was proposed and accepted as part of the handover to BAU. New controls are in place and operating. Identification of Clients with vulnerabilities increase beyond the expected levels and a further phase of work has commenced to ensure support is in place.

Project One value Add

The customer was left with the:

• Ability to bring senior stakeholders together
• Depth of knowledge of regulatory environment
• Calm authority well placed to operate in the environment and bring colleagues along the journey
• Pragmatic approach to delivery to fit with organisational needs.