Consumer Duty is being treated in financial services as a compliance question. I want to say plainly that it is also a financial risk question and that the CFO who is not accounting for it as such is leaving an exposure uncovered that is growing as the regime embeds.
The regime requires demonstrable evidence that the commercial design, from marketing message to financial outcome, serves the customer's genuine interest. That is not a product terms question. It is a commercial system design question that requires a view of the whole customer journey in a level of detail that very few banks and fintechs have built the infrastructure to produce.
The gap between what Consumer Duty requires and what the current commercial reporting can evidence is the exposure. The CFO who can see and measure that gap is exercising oversight the regulation is now specifically asking for. The one who discovers it during a supervision review is in a different position entirely.
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