Scenario:
To support our client’s transition to, and compliance with the Consumer Duty, the bank asked us to create, implement and embed a new First Line Assurance Outcomes Monitoring Framework to demonstrate the delivery of good customer outcomes across the end-to-end customer journey. This included training out the new approach to the Executive Leadership Team (ELT) and the First Line Assurance Team.
Activities:
- Discovery: A review of the bank’s current approach to outcomes monitoring including an evaluation of their existing policies, procedures and controls. We identified a number of gaps and areas for improvement and provided the bank with a range of recommendations. Most notably, that the bank needed to define the end-to-end customer journey and the associated good customer outcomes. All recommendations were presented to the bank’s ELT with approval obtained to proceed to a redesign and ultimately implementation.
- Design and build: The starting point was working with stakeholders across the business functions to undertake ‘end-to end’ customer journey mapping. This included defining the associated good customer outcomes, aligned to the bank’s risk appetite, including developing measures for assessment. Once approved by each Senior Management Function (SMF) responsible for that journey, we proceeded to design and build the new Framework. This included, but was not limited to, the testing methodology, the risk-based sampling approach, the design of management information and defining reporting and governance arrangements. We worked collaboratively with the bank, obtaining their input, feedback and sign-off before proceeding to a pilot and ultimately implementation.
- Pilot: The aim of the pilot was to test, learn and adapt the new Outcomes Monitoring Framework in a live environment. A sample of cases relevant to each testing area were selected to test the process, utilising resources provided by the bank. The pilot was a success and demonstrated that the new approach was able to detect poor customer outcomes, harms and remedial actions that were undetected under the previous approach.
- Implementation and roll-out: We supported the bank with full implementation and roll out. This included designing a 2 day face to face Outcomes Monitoring workshop for all First Line Assurance colleagues, along with practical case study examples. At the end of the workshop, we conducted a formal accreditation of all colleagues to support the bank’s Training and Competency scheme. Separate 1 day sessions were also delivered to the Bank’s ELT and to First Line Assurance Senior Management.
Result:
Square 4 delivered the Outcomes Monitoring Framework, significantly improving the banks’ approach to measuring and demonstrating good customer outcomes. Key highlights include:
- An increase of 73% in the number of issues and themes identified from Outcomes Monitoring.
- Improvements identified and implemented in the bank’s first line policies and controls.
- SMFs can effectively oversight and challenge the results of Outcomes Monitoring, ensuring the bank remains and can demonstrate it is within its’ risk appetite.
- Demonstrating the delivery of good customer outcomes across the bank’s end-to-end customer journey.
