REFLECTING ON THE CONSUMER DUTY
ONE YEAR ON…

LANTERN

Lantern discuss their Consumer Duty journey so far and reflect on the last twelve months. The thought process and actions taken regarding their Annual Report are also considered.

HOW DID YOU FIND THE JOURNEY OVER THE LAST YEAR?

Once we got our heads around the cross cutting rules, and mapped them to each of our business areas, processes and policies, it felt pretty straight forward. Getting to that stage however was a little more difficult as it was extremely time consuming for colleagues, on top of business as usual.

We took the decision from the start to join everyone in the company into the process, to ensure all colleagues understood what the Consumer Duty was, what it was designed for and how it impacted each particular role, and then the wider business.

WHAT WERE SOME OF THE THINGS YOU CONSIDERED?

Our gap analysis began in 2022, with the bulk of the work undertaken in 2023 and a check-in with Deloitte (outsourced internal audit) mid 2023. As the Non-Exec Chairwoman (previous CEO), the business selected me to be our Consumer Duty Champion (CDC). This was due to having knowledge of the operation whilst also bringing independence.

2024 has been a time for adjusting and further embedding, following external feedback and using the Chair/CDC suggested questions on the FCA website, which we incorporated into our report.

WHAT IS INCLUDED IN YOUR ANNUAL REPORT?

The Management Information (MI) required around the Consumer Duty has largely been part of our Board and Executive packs over the last five years, so it made sense to retain and enhance it further, rather than starting again. In November 2023 we began to segregate the focussed Consumer Duty MI into a dedicated ‘CD pack’.

This covers all elements and highlights aspects of the business which could have a harmful impact on the customer. Discussion around the Consumer Duty at Board is given the same amount of airtime as the financial section to ensure we discuss consumer impact thoroughly.

The CD pack contains Key Performance Indicators around kept rates, income and expenditure capture, vulnerability flags, engagement rates, payment values and channels, expression of dissatisfactions and complaints, etc., (mirrored to some of the regulatory data submissions to the FCA). We’ve also included stats on recruitment, agent scores, attrition, training and competency, IT/system infrastructure reports, third party management, data suppliers and incident logs. This whole pack gives a clear picture of our position each month and importantly trends over time.

HOW IS THE ANNUAL REPORT COMING ALONG?

It’s around twenty pages, with fifteen to twenty pages of appendices/back up data/evidence.

The report gives detail on the changes made between July 2023 and today, and focuses on information around operations and service, but also around culture. We recently ran the ‘almost’ final report past Deloitte, as a further sense check which results in a couple of further recommendations. A dry run took place at the June Board meeting, ready for the final report in July.