We get it – the Consumer Duty fatigue is real. And we’re still nine months away from implementation proper.

With the October deadline for implementation plans now behind us (calendar-wise if not in practice), it’s worth thinking about the Consumer Duty to-do lists those plans now generate.

Recent chats with advisers and planners tell us that some feel a bit in the dark about what actual, practical steps they need to take in their business between now and the end of July. Some just feel a general sense of malaise whenever Consumer Duty is mentioned.

So with all that in mind, we’ve been doing some thinking on where the FCA is trying to get to, and the kind of things your firm may need to work through.

Mark chatted this through at the PFS Festival of Financial Planning last week, and what we think a Consumer Duty timeline or process might look like for advisers:

There’s a lot to unpack here, but essentially the ‘inputs’ along the top are the things advice firms and planning practices need to have done if they’re not done already.

This includes someone in your business who is responsible for seeing Consumer Duty through and can challenge where necessary.

At a firm level, it means having a clear idea of who your target clients are, how your service meets their needs, and your own value for money assessment. A lot of this will have been covered through PROD, but just putting it here in case it’s in the ‘done but not documented’ part of your process.

The research and due diligence element is where we at the lang cat can add the most practical support, specifically in the form of Analyser.

Some of the development we have in train is about resurfacing the data we have already, such as provider ratings, and some data doesn’t exist yet but is part of our gameplan to capture – think service level agreements, provider value for money assessments and anything else that will help you form a view of the providers, products and services you’re recommending.

A key focus as we evolve and develop Analyser is all about helping you get through Consumer Duty and beyond. It’s about equipping you with reliable, accurate data which can be put alongside your own experience and way of working, and evidencing it all.

The way we’ve set up Analyser should help lay the groundwork for Consumer Duty, and we’ll overlay as much data and insight as we can to help you demonstrate that you’ve thought about this stuff and that your process stands up to scrutiny.

As Mark said last week: “There's a lot in Consumer Duty, and not all of it is immediately obvious. [It’s about] suitability, and the concept of generating and ensuring ongoing suitability not just for the destination, but for the journey as well.

“Getting all those little points of detail right is, to me, the fundamental building block of ensuring that the duty isn't a pain in the ass.”