Monitor, investigate and take action (where needed…)

Firms will be expected to use data to analyse whether they are achieving good outcomes for their customers. Where data insights show anomalies, e.g. a jump in sales, they should investigate the reason for this. For example, whether it linked to better communications or potential mis-selling.

The FCA has provided an overview of what firms should monitor and the types of data that they could use; but this is not an exhaustive list as the information that firms should use to monitor the outcomes will vary depending on the type of firm, its role in the distribution chain, the nature of the product and the target market.

Firms can also expect to be asked to share their approach to monitoring - information, data, and insights they are planning to gather and what change programmes they have in place to deliver these insights - with the FCA during the implementation period. The FCA has said that it will provide feedback on any useful insights to the industry as a whole to build best practice.