Review Compliance Framework Controls To Ensure Consumer Duty Effectively Implemented
The Client’s Needs
The client is an insurer which distributes volume consumer lines products, primarily through delegated underwriting arrangements. It is very focussed on ensuring all of its oversight and controls are in line with regulatory expectations, with significant investments in its control environments in recent years. With the advent of the new FCA Consumer Duty obligations due to take effect, it wished to ensure that it had the appropriate framework controls and oversight in place to meet these requirements. ICSR was asked to assist the firm with adapting to the regulatory change.
ICSR undertook a full gap analysis of the clients existing framework controls, mapping the final Consumer Duty rules and guidance against the client’s current policies and processes, identifying gaps and producing an implementation plan for addressing those. The implementation plan and report were initially presented to the client’s Compliance Team, prior to board presentation and approval within the FCA timelines.
ICSR deployed resources from its team and Talent Pool to assist the client, which had short deadlines within which to deliver the work. We utilised Talent Pool resource as the specific individual had been involved in some of the earliest work undertaken on the new Consumer Duty rules. The team was overseen by an ICSR director.
The client now has a full understanding of the application of Consumer Duty to its business and a board-approved road-map for delivery of the necessary changes to its compliance framework and product governance structures to ensure compliance with the new rules ahead of the implementation deadlines.