Overview.
A UK-based insurer specializing in high-volume consumer lines products, distributed primarily through delegated underwriting arrangements, had recently undergone regulatory scrutiny. In response, the firm invested in strengthening its operational and control environment, including enhancements to its product governance and oversight framework.
With the Financial Conduct Authority's (FCA) Consumer Duty obligations approaching implementation, the insurer sought independent assurance that its compliance framework was sufficiently robust and aligned with regulatory expectations.
Challenge.
Despite prior remediation efforts and support from third-party providers, the firm recognized the need for a targeted, independent review to:
- Validate the effectiveness of its existing governance and oversight structures
- Identify any residual gaps or areas requiring refinement.
- Ensure readiness for Consumer Duty implementation within FCA timelines.
Solution.
We were engaged to deliver a bespoke Consumer Duty assurance review, designed to minimize disruption while providing actionable insights. The review focused on:
- Evaluating governance structures, committee terms of reference and board-level oversight.
- Assessing documentation related to product performance, service quality and embedding the necessary cultural change.
- Reviewing third-party oversight mechanisms, particularly in the context of its delegated authority distribution arrangements.
The methodology included:
- Initial Engagement: Ensuring alignment of objectives and timelines with the client's leadership.
- Document Review: Desktop analysis of existing materials, including prior consultancy outputs.
- Draft Reporting: Identification of issues and discussion of potential actions.
- Final Reporting: Delivery of a board-ready report setting out findings and recommendations.
Expert Team.
The engagement was led by senior compliance professionals with extensive experience in designing and implementing Consumer Duty frameworks across a wide range of firms. Their combined expertise ensured a pragmatic, high-quality approach tailored to the client's operating model.
Outcome.
The engagement was delivered successfully, on time and within budget. Key outcomes included:
- A clear validation of the client's existing compliance and governance structures.
- Identification of targeted enhancements to provide further alignment with Consumer Duty expectations.
- A board-approved roadmap for ongoing compliance and embedding of the necessary cultural change.
The client is now well-positioned to meet its Consumer Duty obligations with confidence, supported by a framework that reflects both regulatory best practice and operational pragmatism.
Key Takeaway.
Independent assurance provides critical clarity and confidence when navigating complex regulatory change such as the Consumer Duty. By leveraging expert insight and a tailored approach, firms can transform compliance into a strategic asset — ensuring not just adherence, but meaningful delivery of good customer outcomes.
