Context

Our client, the UK subsidiary of a major Middle Eastern bank, had concluded through an internal audit that their implementation of the UK Consumer Duty regulation risked falling short of regulatory requirements.

Eden McCallum was engaged to conduct a thorough assessment of their implementation strategy to date, make recommendations on how to meet the regulator’s expectations, and implement these. The bank had previously worked with a regulatory advisory firm, who had put in place an approach that was overwhelmingly onerous for a medium-sized bank and did not meet the spirit of the regulation.

Approach

Our team began by assessing the Consumer Duty implementation that had been carried out. Our senior consultant was a former FCA leader and was able to rapidly focus the client and the team on core issues.

In close collaboration with the bank’s executive team, we went on to design an appropriate approach for a bank of that size. We also engaged the Board and the executive team to help each NED and executive understand their responsibilities under Consumer Duty regulations.

Finally, the team identified issues that needed to be flagged to the FCA and quantified the likely redress.

Impact

By putting in place a pragmatic approach that was closely aligned with the spirit of the regulation, our work enabled a previously overwhelmed executive team to understand their responsibilities and tackle them in a practical way. It also enabled the bank to be proactive in bringing outstanding issues to the FCA’s attention and addressing them.

As a result, the bank was able to move forward with the confidence that it was fully compliant with the regulation.