69 operating-model decisions a firm has to make under Consumer Duty — and prove it made well. Each is cut two ways: day-to-day (31) vs operating-model change, and cross-financial-services vs industry-specific. The metric informs the decision; the decision gets evidenced.
Our take on the decisions we'd typically expect to see in a firm operating to the principles of Consumer Duty.
| Decision | Type | Scope | Owner (indicative) |
|---|---|---|---|
| Whether an in-period outcome-data finding is material enough to escalate to the board as an unscheduled item, or held for the next scheduled report | Day-to-day | Cross-FS | Board / Risk Committee, convened by the SMF-accountable holder |
| Which 2–3 measures to select, per journey stage, for board-level outcome reporting | Model change | Cross-FS | Product + Operations jointly, ratified by the CD-accountable SMF |
| Whether a fair value assessment's conclusion requires product withdrawal, repricing or remediation, or confirms 'no change required' | Day-to-day | Industry-specific | Board / Product Governance Committee |
| Where to set exception-reporting thresholds that trigger automatic escalation, per outcome metric | Model change | Cross-FS | SMF-accountable holder, ratified by the board |
| Whether to designate a named SMF holder as specifically accountable for Consumer Duty outcomes monitoring | Model change | Cross-FS | Board |
| Whether a vulnerable-customer outcome gap that has persisted across two or more reporting periods should escalate to formal board attestation as an unresolved finding | Day-to-day | Cross-FS | Board |
| Whether to invest in automated, real-time outcome-monitoring technology in place of manual or periodic data pulls | Model change | Cross-FS | Board (capital allocation); SMF-accountable holder (specification) |
| Whether the annual Consumer Duty assessment should stand alone or populate sections within the existing board pack | Model change | Cross-FS | Board / Company Secretary function |
| Whether an identified data-quality limitation should be reported to the board as a named confidence caveat, or left implicit | Day-to-day | Cross-FS | SMF-accountable holder |
| Which single area becomes this period's board deep-dive | Day-to-day | Cross-FS | SMF-accountable holder, ratified by the board |
| Whether a prior-period board action should be marked closed, given the evidence of closure presented | Day-to-day | Cross-FS | Board |
| What human-oversight and bias-testing governance must be in place before an AI/ML capability claim is deployed at the top diagnostic tier | Model change | Cross-FS | Board / Risk Committee, with a named AI-governance owner |
| Whether Consumer Duty accountability should be centralised in a separate function or embedded within each business line's own sprints and decisions | Model change | Cross-FS | Board / Executive Committee |
| Whether an evidence gap is a 'quick win' or a 'strategic capability build', and what priority tier it sits at | Day-to-day | Cross-FS | SMF-accountable holder, with named functional owners |
| Whether to change board reporting cadence for a business line (e.g. quarterly to monthly) | Model change | Cross-FS | Board |
| Whether the customer journey line-of-sight report can currently be produced for the full book, or only a sampled cohort, and whether that's acceptable this period | Day-to-day | Industry-specific | SMF-accountable holder |
| Whether to commission a mock FCA information request to test whether the evidence library can respond within the expected timeframe | Day-to-day | Cross-FS | SMF-accountable holder / Compliance function |
| Whether to invest in a single evidence-library index cross-referenced across outcome areas, replacing scattered departmental ownership | Model change | Cross-FS | SMF-accountable holder |
| Decision | Type | Scope | Owner (indicative) |
|---|---|---|---|
| Whether an individual vulnerable-customer case should escalate to the next severity level (1→2→3→4) | Day-to-day | Cross-FS | Frontline handler (1→2); named specialist/case owner (2→3); senior management (3→4) |
| Whether a vulnerable-customer case should step down in severity level | Day-to-day | Cross-FS | Named case owner; senior sign-off mandatory for step-down from Level 3–4 |
| Whether to build or expand vulnerability-identification triggers for a channel the silent-channel test shows is firing zero flags | Model change | Cross-FS | SMF-accountable holder / Vulnerable Customer function |
| Whether to invest in predictive or behavioural vulnerability analytics to identify customers before disclosure | Model change | Cross-FS | Board (capital allocation); SMF-accountable holder (specification) |
| Whether a journey-stage or segment-level outcome-parity gap requires board-level action | Day-to-day | Cross-FS | SMF-accountable holder, escalating to the board via the deep-dive |
| Where to set the firm's definition of a 'material' parity gap before running the outcome parity monitor live | Model change | Cross-FS | SMF-accountable holder, ratified by the board |
| What reasonable adjustments frontline staff are authorised to make without escalation | Model change | Cross-FS | SMF-accountable holder / Vulnerable Customer function |
| Whether a Level 3–4 case requires senior or multi-disciplinary sign-off before an intervention proceeds | Day-to-day | Cross-FS | Senior management (Level 3); senior management + multi-disciplinary team (Level 4) |
| Whether to invest in specialist vulnerability training (accessibility, bereavement, financial-hardship) for a named team, and at what depth | Model change | Cross-FS | SMF-accountable holder / L&D function jointly |
| Whether a partner's field-force silence (zero vulnerability observations reported back) requires a contractual reporting-obligation fix | Model change | Cross-FS | Third-party oversight committee jointly with the Vulnerable Customer function |
| Whether to expand vulnerability data-sharing agreements across the distribution chain | Model change | Cross-FS | Board / Data Protection Officer jointly |
| Whether a complaint upheld on vulnerability-handling grounds warrants individual competency review only, or a systemic team-level briefing | Day-to-day | Cross-FS | L&D / team manager, escalating to the SMF-accountable holder if systemic |
| Whether to build a defined senior-escalation route out of a relationship manager's individual judgement for Level 3–4 vulnerability cases | Model change | Industry-specific | Board / Wealth business-line head |
| Whether a lending customer's early-arrears pattern consistent with hardship should route directly to Level 2 forbearance options | Day-to-day | Industry-specific | Collections & forbearance specialist team |
| Whether a protection/life claim notification should fast-track directly to Level 2–3 life-event handling rather than build through a Level 1 signal | Day-to-day | Industry-specific | Claims specialist team (bereavement / critical-illness) |
| Whether to invest in cross-channel flag persistence rather than accept a lost flag as a training issue | Model change | Cross-FS | Board (capital allocation); SMF-accountable holder (specification) |
| Decision | Type | Scope | Owner (indicative) |
|---|---|---|---|
| Which communications are prioritised for the first comprehension-testing cycle | Day-to-day | Cross-FS | SMF-accountable holder / Understanding function |
| Whether a communication's comprehension score requires redesign | Day-to-day | Cross-FS | Product + Understanding function jointly |
| Whether a redesigned communication's retest confirms genuine improvement, or requires a further iteration | Day-to-day | Cross-FS | Product + Understanding function jointly |
| Whether a product with a meaningful sale-to-use gap needs a second comprehension test point built in beyond the point of sale | Model change | Industry-specific | Product + Understanding function jointly |
| Whether scenario/decision-accuracy testing is required in addition to recall testing for a given product | Day-to-day | Cross-FS | Understanding function |
| Whether an aggregate comprehension pass conceals a vulnerable-segment or low-literacy-segment failure requiring targeted remediation | Day-to-day | Cross-FS | Understanding function, escalating to the SMF-accountable holder if a segment fails |
| Whether to commission an assessment of what a distributor or intermediary actually explains at the point of sale | Model change | Industry-specific | SMF-accountable holder / Third-party oversight jointly |
| Whether to invest in genuine scenario decision-testing capability and a recruited panel, rather than convenience-panel recall testing alone | Model change | Cross-FS | Board (capital allocation); SMF-accountable holder (specification) |
| Whether synthetic/AI-simulated panel outputs may be used to shortlist draft communications between real-panel testing rounds | Model change | Cross-FS | Understanding function, with AI-governance sign-off |
| Whether a communication may proceed to launch without comprehension testing having been completed | Day-to-day | Cross-FS | Product Governance Committee |
| Whether to invest in low-literacy/ESL-specific panel recruitment given the firm's actual target-market composition | Model change | Cross-FS | Understanding function |
| Whether the firm's approach to prescriptive disclosure content should be redesigned now that the Duty is expected to carry more of that load | Model change | Cross-FS | Compliance + Understanding function jointly |
| Decision | Type | Scope | Owner (indicative) |
|---|---|---|---|
| Whether a partner should move from enhanced monitoring to a formal improvement plan (Stage 1→2) | Day-to-day | Cross-FS | Partner-relationship owner, escalating to senior manager / third-party oversight committee |
| Whether a partner in a formal improvement plan should face commercial consequences (Stage 2→3) | Day-to-day | Cross-FS | Senior management / board sub-committee |
| Whether to exit a partner relationship (Stage 4) | Model change | Cross-FS | Board / most senior committee |
| Whether an event bypasses the graduated Stage 1–4 path and triggers the crisis path immediately | Day-to-day | Cross-FS | Board / most senior committee (same-day) |
| Whether a partner's category classification (1–4) still reflects its actual outcome influence | Day-to-day | Cross-FS | Third-party oversight owner |
| Whether a partner is classified as principal or secondary manufacturer for a given product | Model change | Cross-FS | Board / Product Governance Committee |
| Whether continued reliance on a partner's representations remains reasonable, or a red-flag trigger has invalidated it | Day-to-day | Cross-FS | Third-party oversight committee |
| Whether to formally review or consolidate an informally-grown adviser/introducer panel relationship | Model change | Industry-specific | Board / Wealth business-line head |
| Whether to renegotiate a partner's SLA suite to outcome-aligned measures rather than activity measures | Model change | Cross-FS | Third-party oversight committee / Procurement jointly |
| Whether a commission or remuneration structure that varies with a partner-influenced variable requires structural intervention | Model change | Industry-specific | Board / Product Governance Committee |
| Whether to require a written role-responsibility agreement for a Category 1–2 partner that currently lacks one | Day-to-day | Cross-FS | Third-party oversight owner |
| Whether a partner-caused customer-detriment event meets the FCA-notification trigger | Day-to-day | Cross-FS | SMF-accountable holder / Compliance |
| Whether to invest in named-partner-level data integration, replacing channel-aggregate reporting | Model change | Cross-FS | Board (capital allocation); SMF-accountable holder (specification) |
| Whether contingency/alternative-provider capacity is sufficient before initiating Stage 3–4 action against a partner | Day-to-day | Cross-FS | Senior management / board sub-committee |
| Whether a partner's front-line reporting nothing back on vulnerability (the field-force silent-channel test) requires a contractual reporting-obligation fix | Model change | Cross-FS | Third-party oversight committee jointly with the Vulnerable Customer function |