Consumer Duty Assessment & TCF GAP Analysis – Insurance


It is a Financial Conduct Authority (FCA) requirement that all firms complete a review, at least annually, to assess whether it is meeting the Consumer Duty requirements and is delivering good outcomes to its customers.  A key part of this is assessing, testing and evidencing the outcomes customers are receiving.

We did consider producing a separate document focusing purely on Consumer Duty.  However, when we were working through the FCA papers we identified so many similarities with Treating Customers Fairly we decided to incorporate them into a single Consumer Duty Assessment and TCF GAP Analysis.  This allows firms to complete one document, covering both areas.  Whilst the Consumer Duty supersedes the Treating Customers Fairly Principle 6, it will still apply for business outside the scope of the Consumer Duty.  Also, the TCF principle provides a good standard for firms to continue to embed.

Our Consumer Duty Assessment and TCF GAP Analysis works through all the sections of the sales process and covers what firms should have in place to meet the Consumer Duty outcomes.  It then covers all other areas of compliance, such as complaints handling, vulnerable customers, senior managers and certification regime, training and competence, financial promotions, GDPR, Anti-Money Laundering etc so that firms can assess they are meeting the Duty throughout the business.  The final section is purely on Consumer Duty which provides further guidance on what a firm should have in place.  It also includes a notes section at the bottom of each section which we encourage firms to provide detail of what the firm has in place or any action it needs to take to meet the requirements.

The Assessment can be used as a guide to ensure the firm is meeting all the outcomes and to evidence how these are being met.  There are several ways that Brokers already meet the outcomes.  For example, an adviser can use its research and Suitability Letters as a way to evidence why they are recommending a particular product and is providing the customer with a good outcome as well as evidencing the product is a fair price and value.  The Assessment includes numerous ways, such as this of what can be used so that by the end of completing the Assessment the firm should be more confident of what it already has in place and if there is anything more that should be done.