The FCA's Consumer Duty regime is being managed in your organisation as a compliance requirement. I want to suggest it is also a financial risk management question and that managing it as the former without accounting for it as the latter is leaving a significant exposure uncovered.
Consumer Duty requires demonstrable evidence that the commercial system, from first marketing contact through to financial outcome experienced by the customer, is designed in the customer's genuine interest. That is broader than anything the compliance function was built to monitor and it is broader than the product terms your legal team reviewed.
The CFO who understands where the commercial system falls short of that standard before a supervision review surfaces it is in a different position to the one who discovers it during one. The assessment that identifies those gaps is not an overhead. It is risk mitigation with a verifiable cost and a very real avoided cost that does not appear on any line until it does.
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