Case Study · Conduct & Consumer Duty

A mid-tier wealth manager closes the gap between Consumer Duty policy and Consumer Duty practice.

Board Regulatory Assurance Assessment · Specialist associate input · Retained Advisory follow-through

The Situation

A well-written framework, without proof it was working

The firm, a wealth manager serving retail and high-net-worth clients, had a well-documented Consumer Duty framework and had passed its first annual board statement without incident. The Chair wanted independent confirmation that the framework was genuinely working — not just well-written.

"We know what our Consumer Duty policy says. We don't know, independently of our own compliance function, whether it's actually changing outcomes for the customers who need it most."

The Chair, at the outset of the engagement

What We Did

An independent view, not a compliance review

NJW Consulting was engaged for a Board Regulatory Assurance Assessment, scoped specifically to Conduct & Consumer Duty — independent interviews with four board members, without management present, alongside a full review of board packs, outcome data, and the vulnerable customer identification process.

Reviewed twelve months of board Consumer Duty reporting against the outcome-evidence standard, not process-activity alone
Identified that vulnerable customer identification relied entirely on customer self-disclosure, with no behavioural signal recognition in place
Found that fair value had not been retested since initial implementation, despite a material product change
Engaged a specialist associate for a focused board briefing on how domestic abuse and relationship breakdown present in customer behaviour

What Changed

Three findings, three actions

The Assessment report gave the board an independently evidenced view of where its Consumer Duty framework was strong and where it was structurally exposed.

Frontline training redesigned to recognise behavioural signals of vulnerability — not just wait for disclosure
Fair value reassessment commissioned and completed within eight weeks of the report
A named board member now holds explicit responsibility for vulnerable customer outcome oversight

"We thought we had a good Consumer Duty framework. What we didn't have was proof, independent of our own compliance function, that it was actually working for the customers most at risk of falling through the gaps. Now we do."

The Chair, following the Assessment

What Came Next

From one-off Assessment to standing relationship

Following the Assessment, the firm engaged NJW Consulting on a Retained Advisory basis, providing ongoing independent input to the board's regulatory oversight ahead of each quarterly board meeting — with the specialist associate retained separately for periodic training input.

If your board has a well-documented framework but no independent proof it's working, the next step is a conversation, not a commitment.

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