Consumer Duty MI: When a Green Dashboard Hides Poor Customer Outcomes

A Consumer Duty dashboard can be completely green and still tell you very little about whether customers are receiving good outcomes.

That is the uncomfortable part of outcomes monitoring.

Many firms are now producing increasingly sophisticated MI: complaint volumes, cancellation rates, vulnerable customer numbers, service levels, product performance and satisfaction scores.

But being within tolerance is not the same as demonstrating a good customer outcome.

The problem with averages

Imagine a firm reports that 92% of customers successfully complete an online journey.

On the surface, that looks positive.

But once the data is segmented, a different picture may emerge.

Completion could be significantly lower for customers using accessibility tools. Vulnerable customers may abandon the journey at a much higher rate. One product may generate far more repeat contact than the rest of the portfolio.

The headline metric has not changed.

The understanding of the customer outcome has.

That is where meaningful Consumer Duty monitoring begins.

Compliance should be asking “so what?”

A useful dashboard should not simply tell senior management what happened.

It should help the business understand what the information means.

For material metrics, Compliance should be asking:

· Which customers are experiencing this?

· Are particular customer groups receiving worse outcomes?

· Is the position improving or deteriorating?

· What is driving the trend?

· Could this indicate foreseeable harm?

· What action has been taken?

· How will we know whether the action worked?

The value is not in producing more MI.

It is in interpreting it properly.

Green does not always mean good

RAG reporting is useful because Boards need information that can be understood quickly.

The risk comes when the colour becomes the conclusion.

If a complaint threshold only turns amber above 5%, what happens when complaints remain at 4.9% for six consecutive months?

Technically, the measure remains green.

Commercially and regulatorily, there may still be something worth understanding.

The same applies to vulnerability, cancellations, repeat contacts, claims outcomes, arrears or customer support.

A metric can remain inside appetite while the direction of travel becomes increasingly concerning.

The real test of Consumer Duty MI

Good outcomes monitoring should ultimately help a firm reach one of three conclusions:

We have evidence that customers are receiving good outcomes.

We have identified something that requires further investigation.

We have identified harm, or a risk of harm, and need to act.

If the conclusion is simply:

“Everything is green.”

Compliance should probably ask one more question:

What evidence sits behind the colour?

Because under Consumer Duty, producing the dashboard is not the outcome.

Understanding what customers are actually experiencing is.