Due diligence checklist, United Kingdom
FCA CONC and the Consumer Duty: what to ask a vendor
FCA Consumer Credit sourcebook and Principle 12. FCA. Creditworthiness, arrears handling and customer outcomes meet CONC and the Consumer Duty.
What it is
Creditworthiness, arrears handling and customer outcomes meet CONC and the Consumer Duty.
Who it applies to
Applies to every financial institution in the United Kingdom, when procuring lending and origination, collections and recoveries.
What to ask a vendor, and the evidence to request
| # | Ask the vendor for | Evidence to request |
|---|---|---|
| 1 | Creditworthiness and affordability assessments recorded per application | A written statement from the vendor, with the policy, specification or sample that supports it. |
| 2 | Arrears, forbearance and vulnerable customer handling to CONC 7 | Samples of the notices and documents the system produces, and the workflow for hardship, arrears and vulnerable customer cases. |
| 3 | Outcome monitoring data for the Consumer Duty | The reports and data the institution would receive to monitor performance, risk and customer outcomes, with a sample and the frequency. |
In every case
- A named contact at the vendor responsible for this regime, and how the vendor tracks changes to it.
- Which named customers the vendor already serves under this regime, as references you may call.
This checklist is a starting point for a procurement team, not legal advice. Read it with the regulator's own page, your institution's policies and your legal and risk teams; the regime may have changed since the date on this document.
Next
- Every checklist, by country
- What a market scan is and how to run one
- Have Vederca run the procurement: the regime goes into the register as a must-have