The FCA's Consumer Duty is now over two years old. For most regulated lenders, debt collection agencies and servicers, the initial compliance programme is complete: policies updated, board sign-off obtained, MI frameworks refreshed. But Consumer Duty is not a project you complete. It's an ongoing standard — and the evidence requirement doesn't stop at the policy layer.
The Benchmark's Compliance & Duty assessment focuses on exactly this: not whether you have the right policies, but whether you have the operational evidence that those policies are working.
What 44 Signals Actually Look For
The assessment covers outcomes monitoring, vulnerable-customer handling, CONC compliance and evidence — in that order, because that is the order in which the FCA will scrutinise them.
Outcomes monitoring signals ask whether you are actually tracking what happens to customers at the end of their journey with you. Not just resolution rate, but: did the customer in a payment arrangement maintain it? Did the customer identified as potentially vulnerable receive the appropriate treatment, consistently, across every channel they used?
Vulnerable-customer signals go beyond the identification question. Most operations now have a process for flagging vulnerability. The harder question — and the one the assessment targets — is whether that flag travels consistently through every downstream system and interaction. If an agent identifies vulnerability on a call, does the self-serve portal reflect it? Does the next communication reflect it? Inconsistency here is a CONC issue, not just a process one.
|
The evidence problem: The FCA's approach to Consumer Duty supervision is MI-first. They want to see data that demonstrates your operation delivers good outcomes — not a description of your processes. If your MI can't answer 'what proportion of customers in financial difficulty received forbearance where appropriate, and how quickly', that is a gap — regardless of whether your policy says you offer it. |
CONC — the Consumer Credit sourcebook — governs how regulated firms must treat customers across the collections and lending journey. The Compliance & Duty assessment includes signals specifically targeting CONC compliance in practice: not just whether your policies reference CONC, but whether your operations are consistently delivering against it.
Common gaps this surfaces: inconsistent forbearance application across channels; customer communications that are not in plain language; affordability checks that are documented but not integrated into the decision logic. Each of these is a CONC risk. Each of them shows up in the signals.
What the Peer Comparison Reveals
Compliance is an area where COOs often expect to be above average — because compliance failures tend to be visible and corrective. What the peer comparison frequently reveals is that the MI layer is weaker than expected: firms have good processes but limited ability to evidence them at scale.
The scatter plot for this assessment maps your position against peers who have taken the same assessment. If you are above average on process maturity but below average on outcomes evidence, the action list will sequence evidence-building first — because that is the gap that creates regulatory exposure.
Using the Results Constructively
The Compliance & Duty assessment results are well-suited to three audiences: your compliance function (to validate their current programme), your board (to demonstrate that compliance posture is benchmarked and prioritised), and your internal audit team (to provide a structured view of gaps before a formal review).
It does not replace a compliance audit. But it gives you something a compliance audit cannot: a peer comparison. Knowing that you are in the bottom quartile on outcomes monitoring — relative to anonymised UK peers — is more actionable than knowing you have a gap in the abstract.