FCA Multi-Firm Review · December 2024 · 180 firms assessed

The Consumer Duty operating system
your firm needs.

Meet every PRIN 2A obligation. Prove every one in a few clicks. The FCA-ready Annual Board Report drafted from your live record in 60 seconds.

Trusted by 250+ UK-regulated firms · Built by compliance professionals, for compliance professionals.

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4 Outcomes & Cross-Cutting Rules
238-Question Assessment
Annual Board Report (Otto)
Fair Value Assessments
Vulnerable Customer Register
15 A8 Monitoring Areas
Board members reviewing Consumer Duty outcomes

“Our last Consumer Duty Board Report took eight weeks and a consultant. Otto drafts it from our live record and the board signs it off the same afternoon.”

Sarah Whitfield
Sarah Whitfield
Compliance Director (SMF16) · Wealth Management Firm
The FCA Verdict · Multi-Firm Review · December 2024

The gaps the FCA found in nearly every firm. Closed with RegTechPRO.

The FCA's December 2024 Multi-Firm Review named the same six gaps in firm after firm — board challenge, MI quality, vulnerability, fair value, consumer understanding and support journeys. Here's what the regulator flagged, and how the platform closes each by default.

Finding 1 · Governance
Board minutes showed agreement, not challenge.
The FCA expected evidence of robust board challenge, with assumptions tested and alternative views recorded. Many firms produced minutes that simply noted approval.
Agenda item 1✓ Approved
Agenda item 2✓ Noted
Agenda item 3✓ Agreed
PRIN 2A.9 · Governance
Finding 2 · Outcomes Monitoring
Reports described activity, not outcomes.
Consumer Duty is an outcomes regime. Yet most MI still reported on inputs (policies updated, training completed), not evidence that good outcomes were delivered.
Policies updated✓ 47
Training completed✓ 89%
Good outcomes deliverednot measured
PRIN 2A.8 · Monitoring
Finding 3 · Vulnerability
Few firms could segment outcomes by vulnerability.
The FCA asked: “Show me outcomes delivered to vulnerable customers versus the rest.” Most firms couldn’t. The data existed; the analysis didn’t.
All customers94%
Vulnerable customersnot analysed
FG21/1 · Vulnerability
Finding 4 · Price & Value
Fair value assessments were stale.
Assessments completed at launch in 2023 were still in use two years later. The FCA expects regular refresh, especially for closed products and renewing books.
Last FVA completedQ2 2023
Age of assessment21 months
FG22/5 Ch.7 · Price & Value
Finding 5 · Consumer Understanding
Understanding was assumed, not evidenced.
Firms believed customers understood key documents, terms and risks. Few had tested comprehension. “We think it’s clear” isn’t “we have tested it is clear.”
Customer comprehension tested✗ No
Assumed to be clear✓ Yes
FG22/5 Ch.8 · Understanding
Finding 6 · Consumer Support
Support paths were designed once, never retested.
The complaints journey, the cancellation route, the vulnerability path. Many firms still had 2022 designs with no friction analysis, no user testing.
Cancellation journey designed2022
Last user-testedNever
FG22/5 Ch.9 · Support

If any of these findings land uncomfortably close to your firm, you’re exactly who we built the Consumer Duty Hub for.

Features

The Consumer Duty operating system your firm needs.

Three things make it the OS, not a tool. Nine capabilities turn it into the audit-grade PRIN 2A.9 record the FCA's last two reviews said most firms lack. One module covering every Consumer Duty obligation — live, attested, year-locked, provable in a few clicks.

Three ideas a year-end spreadsheet can't match.

Most Consumer Duty tools are digital versions of the same year-end PDF. Consumer Duty Hub is built on three principles that change the maths entirely: who owns the answer, who sets the bar, and how long the record lasts.

You attest. Otto drafts. You sign.

The supervisory-grade division of labour the FCA wants to see. Humans own the input — 238 attestations, your MI, your evidence. Otto drafts the 29-page board report. Humans own the sign-off. Three architectural write-gates enforce the split.

Static year-end PDF: stale by month two, no live audit trail
Consumer Duty Hub: humans in, humans out, AI in the middle
PRIN 2A.9 · 3 write-gates

Your RAG. Your bar.

A vulnerable-heavy firm can demand 95% on Consumer Support. A simple-product firm can keep all four outcomes at 85%. Every answer carries a published, consistent scoring rubric — your benchmark, evidenced, defensible to a supervisor.

Other tools: generic 85% threshold, the same for every firm
Consumer Duty Hub: editable per outcome, scored to your bar
Editable per firm · Auditable

Live all year. Locked forever.

Consumer Duty stops being a Q1 scramble. Attest as evidence arrives, MI lands monthly, Otto can produce an interim board report any time. When the year closes the data locks read-only — reproducible three years later when the auditor revisits.

Year-end consultancy: 8 weeks of work, frozen artefact, drift by month two
Consumer Duty Hub: continuous attestation, instant report, immutable lock
QoQ trend · Immutable year-lock

Nine capabilities turn this into the system the SMF16 runs from.

Built for the audit trail PRIN 2A.9 was written for. Every capability ships in the module — no tier gate, no add-ons.

1 Audit & attestation When the FCA asks "who, when, why" — you click once.
Per-question audit trail

Every answer carries an initials chip showing who attested, when, and what changed. Click for the full diff history. The supervisory-grade chain from individual sign-off to board sign-off — visible end-to-end.

Named attestor · Year-locked
Evidence linkage

A paperclip beside every question. Upload once — file lands in your Drive AND the central Evidence Register AND links back to the question. Coverage RAG on the dashboard. Otto cites uploaded evidence by name.

Drive-native · Coverage RAG
Year-on-year lock

Every closed year auto-locks into a permanent read-only snapshot. The 2026 board report you signed still looks identical in 2029 when the auditor revisits. Unlock with a reason — that's logged too.

Audit-grade · Calendar-locked
2 Outcomes & reporting From live record to signable board report in 60 seconds.
29-page Annual Board Report

Otto drafts every section from your live record — section-by-section to FG22/5. Your attestations become evidenced narrative, real MI becomes real prose, vulnerable-customer outcomes are split out and cited. PDF, signable, in 60 seconds.

FG22/5-mapped · 60 seconds
Year-on-year diff

A 5-tab lightbox shows attestation changes, score deltas, gap movements, product changes and governance evolution. Otto's Executive Summary leads with what changed — automatically — so the board reads the deltas first.

5-tab diff · Auto-cited
Adverse outcome register

Poor outcomes — with or without a complaint attached — logged with detection source, root cause, customer count, £ detriment, remediation. Otto flags zero count as suspicious for any customer-facing firm. The under-detection check most firms don't realise they need.

8 detection sources · Systemic flag
3 Live operations The reassessment layer the FCA expects between annual reports.
Trigger events log

Pricing change. New product. Personnel change. Regulatory letter. The 12 events that should prompt a CD reassessment — logged with date, owner, action and status. Cited by Otto in the Future Strategy section.

12 event types · Status workflow
238-question assessment

15 areas, 238 firm-level questions, plus 54 questions per product. Each attested by a named owner, scored against your bar, mapped to PRIN 2A and FG22/5. The depth the FCA expects — already structured, ready to answer.

15 areas · 54 per product
Vulnerability segmentation

The FCA's December 2024 question — "show me outcomes for vulnerable customers versus the rest" — answered. Outcomes split, evidenced and reported by vulnerability flag. The analysis 180 firms couldn't produce, ready by default.

FG21/1 · Outcomes split

Every Consumer Duty outcome. One module.

Four outcomes, three cross-cutting rules, every product line. 238 firm questions, 54 per product, all feeding Otto's 29-page Annual Board Report.

238
Firm-level questions
54
Per-product questions
15
Assessment areas
4
PRIN 2A outcomes
29
Pages, board report
Products & Services PRIN 2A.4
Price & Value FG22/5 Ch.7
Consumer Understanding FG22/5 Ch.8
Consumer Support FG22/5 Ch.9
Outcomes Monitoring PRIN 2A.8
Annual Board Report PRIN 2A.9
Vulnerability FG21/1
Manufacturer / Distributor PROD
Closed Products PRIN 2A (closed)
Plus: Board Challenge Record (the FCA-flagged gap most firms lack) · 12 trigger event types for inter-year reassessment · 8 adverse-outcome detection sources · 5-tab year-on-year diff · editable RAG thresholds per outcome.

Enterprise quality. SME pricing.

Affordable, modular monthly pricing · No tier gate. No add-ons. No setup fee.

See it in your firm
The Solution

Every obligation. Provable in a few clicks.

A glimpse of the operating system the SMF16 works in every day. 238 firm-level questions, 54 per product, all 15 assessment areas — each attested by a named owner. MI, gaps, evidence, training and the Board Challenge Record feed Otto's 29-page Annual Board Report, mapped section-by-section to FG22/5. Click any tab to look inside.

Consumer Duty Dashboard — compliance health, outcome performance radar and 3LOD across one screen

A 30-second status check for the whole firm: Compliance Health donut, Outcome Performance radar against your own thresholds, 3LOD scoring, training completion and live gap and evidence registers — every PRIN 2A.9 obligation, one screen.

Consumer Duty attestations — 238 firm-level questions, FG22/5-mapped, named-owner audit trail

238 firm-level attestations and 54 per-product Fair Value questions — each with a named owner, signature, rationale and evidence link. FG22/5 chapter-for-chapter, year-on-year locked, audit-ready.

Consumer Duty evidence capture — Drive-linked documents tagged to the source FG22/5 question

Every attestation is backed by Drive-attached evidence the regulator can drill into — minutes, MI, journey reviews, vulnerability data — tagged to the source FG22/5 question and lock-stamped at sign-off.

Consumer Duty registers — gap, adverse outcome, trigger events and root cause analysis logs

Every Consumer Duty register in one place: Gap Register, Adverse Outcomes log, Trigger Events log, Complaints and Root Cause Analysis history — each linked to named owners and Drive-attached evidence, year-on-year traceable.

Consumer Duty Key Metrics — complaints, vulnerability, fair value, training and foreseeable harm

Complaints volume, vulnerability share, fair value gaps, training completion, foreseeable-harm flags — benchmarked against your own thresholds, RAG-rated for the board, drillable to the underlying record.

Consumer Duty compliance reviews — 3LOD and First-Line QA tracking

Three-Lines-of-Defence reviews and First-Line QA scheduled and tracked end-to-end. Sample sizes, pass rates, breach themes and corrective actions — all evidenced for the supervisor.

Consumer Duty Annual Board Report — FCA-ready, drafted by Otto in 60 seconds

The 29-page PRIN 2A.9 Annual Board Report drafted by Otto AI from your live data in 60 seconds. 13 sections plus Sign-Off and Challenge Record. Review, sign, export — board-ready, supervisor-ready.

Consumer Duty in dark mode

Long compliance days, gentler on the eyes. A full dark mode across every Consumer Duty screen — same WCAG-compliant contrast, same audit accuracy, just easier to live in.

The 29-page Annual Board Report

The FCA-ready Annual Board Report. Drafted by Otto. Signed by your board.

The same regulatory document the FCA asks for under PRIN 2A.9 — produced in 60 seconds, not eight weeks. 13 sections, named attestors, the Board Challenge Record the FCA's last two reviews said most firms lacked, and a year-end lock that makes 2026's report still reproducible in 2028.

Every section. Every FCA anchor.

Otto drafts all 13 sections of the PRIN 2A.9 annual report from your own firm’s data: attestations, MI, complaints, vulnerability outcomes, training, gaps. Each section is explicitly mapped to its FG22/5 chapter, so the supervisor can trace the regulatory origin of every claim.

13
Sections drafted
29
Pages produced
238
Attestations synthesised
<2min
To first draft
1
Executive Summary
FG22/5 Ch.1
2
Governance & Oversight
PRIN 2A.9
3
Culture & People
SYSC 5
4
Products & Services
FG22/5 Ch.6
5
Price & Value
FG22/5 Ch.7
6
Consumer Understanding
FG22/5 Ch.8
7
Consumer Support
FG22/5 Ch.9
8
Vulnerable Customers
FG21/1
9
Complaints & Root Cause
DISP
10
Distribution & Third Parties
PRIN 2A.3.8R
11
Monitoring & MI
PRIN 2A.8
12
Gap Action Plan
Internal
13
Forward Look & Conclusion
PRIN 2A.9
FCA Dec 2024 review · flagged as missing

Named challengers. Dated questions. Logged status.

Exactly the format the FCA expects: live and logged, not reconstructed. Every question raised by a board member or NED is captured with its challenger, its date, the concern, and whether management’s response resolved it.

Challenger Question raised Raised Status
Charlotte Thompson
NED · Audit Committee Chair
How do we know the new closed-book drawdown product is still fair value 21 months after last FVA? Mar 18, 2026 Open
Shivani Patel
SMF1 · CEO
Vulnerability outcome delta is +0.1. Is that within tolerance or do we need tailored action? Feb 24, 2026 Resolved
Marcus Clarke
NED · Risk Committee
2LoD oversight sits at 90%. What’s blocking the last 10%, and when does it close? Feb 11, 2026 Resolved
Jennifer Okafor
SMF2 · Chief Compliance
Consumer Understanding Section 6 relies on assumed clarity. Should we commission comprehension testing in Q3? Jan 29, 2026 Resolved

Three named attestors. One audit trail.

PRIN 2A.9 demands clear accountability. Three roles sign: the CEO (SMF1), the Chair, and the senior compliance officer (SMF2). Once locked, the report is immutable and timestamped. If the FCA knocks in 2028, the 2026 report still opens, question-by-question identical.

SMF1 · Chief Executive
Shivani Patel
Chief Executive Officer
Signed Mar 28, 2026
SMF2 · Chief Compliance
Jennifer Okafor
Chief Compliance Officer
Signed Mar 28, 2026
Chair · Board Oversight
Charlotte Thompson
Board Chair · NED
Signed Mar 29, 2026
Report locked · Mar 29, 2026 · 16:42 GMT Read-only. Source-matched. Reproducible until Mar 2029 audit horizon and beyond.

Your FCA-ready Annual Board Report in 60 seconds.

Click once. Otto drafts all 13 sections of your PRIN 2A.9 Annual Board Report from your live record — board challenge, vulnerability, distribution oversight, fair-value evidence, action ownership — and hands you a signable PDF, trained on PRIN 2A, FG22/5, PROD 4, FG21/1 and PS22/9.

PRIN 2A EXPERT · FG22/5 TRAINED

Your Consumer Duty regulatory research desk and board report author, in one.

Otto does two things. She answers any PRIN 2A, FG22/5 or FG21/1 question — cited and handbook-grounded, in seconds. And she drafts all 13 sections of your 29-page board report from your attested data, flagging Urgent Board Actions as she goes.

  • Answers PRIN 2A, FG22/5, PROD 4 & FG21/1 queries with rule-level citations
  • Drafts the 29-page Annual Board Report in minutes, not weeks
  • Synthesises from your 238 attestations, MI, complaints & evidence
  • Never attests for you: human accountability at input & sign-off
Your Consumer Duty research desk

Ask Otto anything about Consumer Duty. Get a cited answer.

“What does FG22/5 say about distribution chains?” “How should we evidence fair value for a closed-book product?” “What counts as good board challenge under the Dec 2024 review?” Otto answers from the handbook, FG22/5, PROD 4, and your live Consumer Duty Hub data, in seconds, with citations.

  • PRIN 2A, FG22/5, PROD 4 & FG21/1 grounded
  • Cites rules, paragraphs & your own data
  • Reads your 238 attestations & MI live
  • Available across every CD tab
Otto AI
Online · AI Compliance Advisor
How should we evidence fair value for our closed-book drawdown product?

Closed-book products still fall under PRIN 2A.4. Three things to evidence:

  • Comparable market review (FG22/5 §7.37): even without new sales, compare charges & outcomes against live equivalents
  • Egress fairness: exit charges, transfer blockers, sludge practices (PRIN 2A.6.2R)
  • Legacy customer monitoring: vulnerability rates, service responsiveness, complaint differentials

Your Capped Drawdown product has 1 evidence item logged. I'd add a comparable-market review before the May board.

Drawn from: PRIN 2A.4 · FG22/5 Ch.7 · Your Evidence Register
Ask Otto anything about Consumer Duty…

Otto drafts your 29-page Annual Board Report from your live data.

She drafts all 13 board report sections from your live Consumer Duty data, flags Urgent Board Actions, and answers any PRIN 2A question your team asks. See her draft your board report in a live demo.

Every obligation met. Every one proven.

From wealth managers to consultants: how firms are replacing the Consumer Duty scramble with a live, year-round record.

5.0

We used to dread the Consumer Duty annual board report. Five weeks of scrambling in Q1, pulling MI from three systems, stitching it into a narrative nobody trusted. Now it's a running record. Otto drafts the 29 pages from what we've attested all year. Our board got the cleanest CD paper they've ever seen, and I got my Januarys back.

Dimitri Vasilis
Dimitri Vasilis Head of Compliance, Wealth Management Firm
4.7

We trialled Consumer Duty Hub and got a better-structured 29-page draft inside a fortnight. The Board Challenge Record alone is worth the subscription. That's the exact format the FCA flagged as missing in the Dec 2024 review.

Victoria Ashworth
Victoria Ashworth CEO (SMF1), Retail Investment Firm

Consumer Duty Hub: Questions Answered

Everything you need to know about Consumer Duty Hub, Otto's board report, and how it sits inside PRIN 2A.

Does Otto really draft the whole 29-page board report?
Yes — all 13 sections (Executive Summary to Conclusion) plus suggested Board Recommendations, written from your attested data: 238 answers, per-product fair value, MI, complaints, vulnerability outcomes, training, gaps and evidence. You review, sign and export; Otto never attests for you. First draft in under 2 minutes.
Is it mapped to FG22/5 and PRIN 2A.9?
Every section, explicitly. Section 4 (Products & Services) maps to FG22/5 Chapter 6. Section 5 (Price & Value) to FG22/5 Chapter 7. Sections 6–7 to Chapters 8 & 9. Vulnerability maps to FG21/1. Governance maps to PRIN 2A.9. Distribution maps to 2A.3.8R. Each section's in-platform guidance panel shows the exact FCA good-practice anchors it covers, so you can see why content appears where it does.
Can we edit the draft before it goes to the board?
Yes. Every section is editable, and Otto can regenerate any individual section if your underlying data changes. The platform keeps a Board Sign-Off record with three named attestor roles and a Board Challenge Record for questions raised and resolved. The FCA's Dec 2024 Multi-Firm Review specifically criticised firms for weak challenge. Consumer Duty Hub gives you the exact format regulators want to see.
How often is the report produced?
Annually, as PRIN 2A.9 requires. But the data behind it is live year-round: you attest progressively as evidence becomes available, MI lands monthly, and Otto can produce an interim draft at any point. That's useful for quarterly board packs, audit committee papers, or ad-hoc supervisor queries. Year-end stops being a scramble and becomes a sign-off.
What exactly does the 238-question assessment cover?
15 areas covering all four FCA outcomes, the three cross-cutting rules, governance, vulnerability (20 Qs, FG21/1 + TEXAS), three lines of defence, monitoring, complaints, distribution and forward look — plus per-product Product Review (54 Qs per in-scope product).
We have six products. Do we need to answer 54 questions for each?
Yes. That's by design, and it's what PROD 4.2 and FG22/5 Chapter 7 expect. The module scaffolds each assessment for you: target market, charges and value drivers, distribution chain, vulnerability impact, complaints drivers, outcome metrics. Closed-book products still need a Fair Value Assessment and appear correctly on Section 4's Products Table. Six products = 324 product-specific attestations, all linked to the Evidence Register.
Does the vulnerability capture align with FG21/1 and TEXAS?
Yes. The 20-question Vulnerable Customers area is structured around FG21/1's four drivers of vulnerability plus the TEXAS framework (Thank, Explain, Explicit consent, Ask, Signpost). The Vulnerability Spotlight tile tracks customers identified, tailored support provided, and, critically, the outcome differential versus non-vulnerable customers. Outcome-differential tracking is exactly what Dec 2024 Multi-Firm Review flagged as under-evidenced.
How does it integrate with the rest of RegTechPRO?
Three live cross-module flows: (1) Complaints from the CMP auto-sync into the CD Complaints tile and Section 7 of the Board Report; (2) the 15 A8 CD monitoring areas are pushed into your Compliance Monitoring Plan on day one; (3) evidence items tagged Consumer Duty surface in the CD Evidence Register automatically. One platform, one set of data.
Can I set my own RAG thresholds?
Yes. This is a genuine differentiator. Most CD tools ship with platform defaults. Here you set your own target per outcome: Products, Price, Understanding, Support. A vulnerable-heavy firm can demand 95% on Consumer Support; a simple-product firm can set all four at 85%. The Outcome Performance radar tracks you against your benchmark, not ours. Scoring is consistent: every answer option has a published numeric score.
How much does Consumer Duty Hub cost?
Priced as a modular monthly subscription. See regtechpro.co.uk/pricing for the full modular calculator.
Do I need the whole RegTechPRO platform, or can I just have Consumer Duty Hub?
Consumer Duty Hub is an add-on to a RegTechPRO subscription. It sits inside the platform so it can pull complaints, evidence, training and monitoring tasks from other modules. The base subscription includes the free foundation Consumer Duty draws on to function end-to-end.
How long does setup take?
Under a day for a small firm. The module ships pre-seeded with all 238 firm-level questions, the 15 A8 CMP areas, the 6-subject training taxonomy, the 15-type Evidence Register vocabulary and the 9-field Monthly MI schema. You add your in-scope products, your target thresholds per outcome, and start attesting. No migration project, no framework to design from scratch.
I'm a compliance consultant. Can I run this across my client book?
Yes. It's one of the module's strongest use cases. Each client has its own workspace with its own 238-question assessment, its own MI, its own board report. You run the production line; they retain accountability. The historical year-lock means 2026 reports are still reproducible in 2028, so when auditors revisit a prior year the source data matches to the question.
Does Otto ever attest on my behalf?
No. Otto synthesises; she never attests. The design principle is deliberate: human accountability at the input (your 238 answers), AI efficiency in the middle (her 29-page draft), human sign-off at the output (three-role Board Sign-Off form). This is the supervisory-grade division of labour the FCA would want to see, and it matches PRIN 2A.9's clear accountability expectations.
What does Otto actually quote when she cites?
The handbook sources that apply: PRIN 2A, FG22/5, PROD 4.2, FG21/1, PS22/9, DISP, SYSC and SM&CR — plus the Dec 2024 FCA Multi-Firm Review. And your own data: the exact evidence item, MI month or assessment answer behind each claim.
How reproducible is an old board report?
Fully reproducible for at least three prior reporting years, and ideally indefinitely. When a reporting year closes, its data locks: read-only, no accidental overwrites, still exportable. April 2027 auditors can open your 2026 report and the source data underneath still matches, question-by-question. This is how the platform supports s.166 reviews or historical FCA queries without needing to rebuild the year.
What audit trail do inspectors see?
Every answer is timestamped with user, date and edit history. The Evidence Register ties each claim to a dated artefact; the Board Challenge Record logs named challengers; training records map to the 6 CD subjects; complaints and RCA keep full status histories. Ask "why are we at 92% on Good Faith?" and you get a question-level, evidenced answer.

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