How MARS addresses the FCA’s feedback on Consumer Duty board reports

We built the MorganAsh Resilience System specifically to help firms meet FCA Consumer Duty requirements on vulnerability. Here is how it matches up to the FCA’s feedback on the five areas for improvement needed in Consumer Duty board reports.


👎 Some firms did not have data of sufficient quality to justify their conclusions, or to give governing bodies adequate assurance that they had met their Consumer Duty obligations. Some firms did not provide sufficient explanations with their management information to clearly demonstrate good customer outcomes.

👍 MARS identifies, classifies, monitors and reports on characteristics of customer vulnerability in such a way that it can be used to compare outcome monitoring data. Its unique classification system ensures that customer vulnerability data is both objective and consistent, providing reliable management information for boards. Too many firms focused purely on training, neglecting data collation and reporting.


👎 Some reports did not contain evidence that the appropriate amount and types of information had been shared between the firm and third parties across the distribution chain.

👍 MARS enables the sharing of information between intermediary and manufacturer. Its comprehensive classification system of customer vulnerability means that all parties can understand what is going on – and can share data between firms, as part of the monitoring obligation. MARS is independent of firms and products – it’s purely customer-focused.


👎 Some firms did not show that they adequately considered the outcomes for different groups of customers, including vulnerable ones.

👍 MARS’s unique classification of characteristics of vulnerability enables consistent management information that can be correlated against outcome reporting data at different granularity levels of data, and across different areas, for example: product or distribution channel.


👎 It was not always clear that there had been any effective challenge from firms’ governing bodies on the content of the reports – for example, through the minutes of board meetings.

👍 The whole concept of customer vulnerability management is new; it is not until people see data from MARS do they realise what is possible. To use a Henry Ford analogy, many people are asking for a faster horse – MARS is like providing a car.


👎 Some action plans and improvements were not accompanied by details such as timescales, action owners, or clarity on the type of data that would evidence good outcomes.

👍 The MARS roll-out proceeds in stages; we've collaborated with multiple firms, to help them plan their implementation phases and meet the FCA’s requirements.


😊 In summary: without a comprehensive classification methodology, and systems to store and communicate this data, firms will struggle to meet the FCA’s requirements.

Andrew Gething

Andrew is the founder and managing director of MorganAsh. Andrew, a recognised consumer vulnerability specialist and champion, is the driving force behind the award-winning consumer vulnerability management tool, MARS – adopted in the financial services, credit and utilities sectors.

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