Start with the FCA outcomes
The Duty includes outcomes concerning products and services, price and value, consumer understanding and consumer support. Firms should consider which parts of their customer journey and evidence demonstrate how those outcomes are being addressed.
Read the FCA Consumer Duty overviewAsk what the file can show
Can an authorised reviewer follow the journey? Can they identify the product, communications and material customer information? Are important decisions, support needs and follow-up actions recorded in the appropriate controlled systems? The answer will vary according to the firm's role and process.
Look beyond individual documents
A signed form may be relevant evidence, but it should not replace consideration of customer understanding or outcomes. Dates, versions, communications, tasks and exceptions can provide essential context around what took place.
Connect files with outcome monitoring
The FCA explains that firms need to identify data sources for evidence against Duty outcomes and conduct at least annual governing-body assessment. Structured Deal File information may support that management view, alongside complaints, cancellations, vulnerable-customer information and other relevant data.
Keep responsibilities clear
Auto eDocs can support record keeping and oversight, but it cannot determine whether a firm's controls satisfy the rules. Confirm requirements against the FCA Handbook and current guidance, and obtain qualified compliance or legal advice for your circumstances.
