Consumer Duty is now an embedded supervisory expectation, not a one-off implementation project. Firms need clear evidence that products, pricing, communications, support, and governance deliver good outcomes in practice. RRCA helps firms strengthen fair value assessments, Board reporting, customer outcome monitoring, and remediation where Consumer Duty controls are not yet giving management enough confidence.
Consumer Duty & Fair Value Reviews.
Why Consumer Duty and Fair Value Need Active Review
Consumer Duty requires firms to move beyond policies and implementation plans and show that they are delivering good outcomes for retail customers in practice. That means governance, management information, product review, customer communications, support, and distribution oversight all need to work together. If they do not, the firm can struggle to evidence that it understands where foreseeable harm, poor value, or customer friction is arising.
Fair value is often the area where firms feel least confident. It is not just a question of price level or margin. It requires firms to assess whether customers receive a reasonable relationship between what they pay and the benefits they actually get, taking account of product design, limitations, distribution arrangements, charges, add-ons, service quality, and the real customer journey.
Independent review is particularly valuable where Boards want stronger assurance, first annual or follow-up Board reporting needs to become more robust, or product and distribution changes have made earlier Consumer Duty work stale. A well-scoped review can help management test the quality of existing evidence, identify blind spots, and prioritise practical remediation.
Fair value reviews
Board report support
Outcome monitoring
Remediation analysis
Distribution oversight
Board Reporting
How RRCA Supports Consumer Duty and Fait Value
Consumer Duty Gap Analysis
We review whether your Consumer Duty framework is genuinely embedded across governance, product design, communications, support, monitoring, and escalation. This includes testing whether the business can evidence good outcomes clearly and whether current documentation matches how decisions are actually being made.
Board Report & Governance Support
We help firms improve the quality of annual Consumer Duty reporting and wider governance materials so Boards receive a clearer picture of customer outcomes, risks, remediation status, and management challenge. The goal is to make reporting decision-useful, not just compliant in form.
Customer Outcome Monitoring & MI
We support firms in strengthening the data, indicators, and escalation routes used to detect emerging harm, poor value, support friction, complaints trends, or vulnerable customer concerns. Better MI should help management act earlier and explain more clearly why risks are or are not being accepted.
Fair Value Assessments & Price and Value Reviews
We help firms strengthen fair value methodology, challenge assumptions, review fees and features, test outcome evidence, and assess whether pricing and product benefits remain reasonable in practice. This can include support on product cohorts, distribution costs, add-on structures, and whether management information is sufficient to support conclusions.
Target Market, Distribution & Product Governance Reviews
We review whether products are reaching the intended market, whether distributors and intermediaries are supporting good outcomes, and whether product governance remains proportionate as products, customer cohorts, or sales channels evolve. This is particularly useful where firms rely on third parties or have changed distribution strategy over time.
Consumer Duty Remediation
Where reviews identify gaps, we help firms prioritise remedial actions, refine governance, strengthen product review cycles, improve fair value evidence, and align internal ownership across first line, second line, senior management, and the Board. The emphasis is on practical remediation that can stand up to supervisory scrutiny.
What Good Consumer Duty Governance Includes
A strong Consumer Duty framework should help the firm understand what customers are actually experiencing, where poor outcomes may be emerging, and whether pricing, communications, support, and distribution remain appropriate over time.
Outcome-focused MI
Management information that goes beyond volume or sales data and helps identify real customer outcomes, value concerns, and emerging harm.
Defensible fair value methodology
Assessments that consider charges, benefits, limitations, distribution arrangements, and actual customer experience not just assumptions.
Board challenge and action
Clear governance that shows the Board is receiving meaningful reporting, asking the right questions, and tracking remediation where issues are found.
Product and distribution oversight
Ongoing review of target markets, channels, intermediaries, vulnerable customers, complaints, and support journeys so the framework remains current.
Frequently Asked Questions - FAQ
What is a fair value assessment under Consumer Duty?
A fair value assessment is the firm’s assessment of whether the price a customer pays is reasonable compared with the overall benefits they receive. It should look beyond headline price and consider charges, exclusions, features, distribution costs, service quality, limitations, and whether customers are genuinely receiving value in practice.
If your current methodology feels too high level or difficult to defend, RRCA can help strengthen the assessment and the evidence behind it.
Do all firms need a Consumer Duty Board report?
Where the rules apply, firms should have annual governing body review and approval of Consumer Duty reporting. In practice, the annual report is an important governance tool because it helps management and the Board assess whether the Duty is really embedded and whether remedial action is needed.
What does the FCA mean by fair value?
The FCA’s concept of fair value is not a fixed price cap. It is about whether retail customers are paying a reasonable price compared with the benefits they receive from the product or service. Firms need to be able to evidence that customers are getting a fair deal and revisit the assessment where that evidence is weak.
Who is subject to the Consumer Duty requirements?
The Consumer Duty applies to FCA-regulated firms that manufacture, distribute, advise on, or service products and services for retail customers, including firms involved at any stage of the customer journey.
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At RRCA we provide a comprehensive and tailored service, meeting individual needs and FCA obligations. Whether you are a start-up or an established firm, our expert consultants are here to provide guidance and support.
You can find ample information on our website or if you prefer, simply contact us for an obligation free and confidential discussion about your needs.