OneSavings Bank

Our experts worked at pace to enable the bank to meet this initial deadline and then help to refine and deliver its programme. Our deep expertise in financial regulation – both technical and practical – enabled the bank to hit a series of compliance deadlines and shape the innovative customer-centric culture that the new Consumer Duty demands.

The right financial products, sold responsibly, help people achieve the financial security and outcomes they want – from buying a home to saving for life’s big events. OneSavings Bank (OSB) specialises in offering products for customers underserved by mainstream banks, including mortgages for people who are self-employed or have adverse credit. The new Consumer Duty provides an opportunity to double down on this focus on customer needs. 

The Consumer Duty requires firms to create good outcomes for customers at every point – from ensuring products offer fair value, to providing clear information pre-sale and high-quality support post-sale, to handling complaints efficiently. The FCA has been clear that compliance is by no means a box ticking exercise; it demands a fundamental shift in culture so that doing the right thing by customers is at the heart of the business.

Making the right decisions, right from the start

For OSB, the challenge was to understand this shift and develop comprehensive plans to achieve it. Time was short. Within four months of the new rules being published, OSB needed a board-approved plan in place. Within one year, all current products and the processes surrounding their sale had to be compliant. Within two years, this will apply to all products the bank had ever sold.

“The new regulation created an opportunity to serve our customers better than ever before. But it introduced new regulatory concepts and demanded widespread change across the retail banking and lending sector that we didn’t have long to prepare for,” explained Jon Hall, Group Managing Director, Mortgages & Savings, OSB Group. “We needed expert support to test our thinking, understand how our competitors were approaching the challenge, and ensure we had a robust, pragmatic, and customer-focused plan for delivery.”

Our specialist team brought the right expertise: a mix of regulatory experts, including ex-regulators, and specialists in delivering complex regulatory change.

Combining technical expertise with a practical focus

With the first deadline pressing, we carried out a rapid review of OSB’s plans for implementing the Duty, identifying gaps and recommending actions to address them. “We worked closely with OSB to develop a pragmatic solution, achievable within the Financial Conduct Authority (FCA) deadlines, and in line with what the bank’s peers were doing,” explains PA’s Caroline Wayman, Risk & Regulation expert. She continued, “our ability to bring insights from the experience of our team and our wider work supporting other firms on Consumer Duty was invaluable.”

With the right plan in place, we moved to designing the bank’s approach to assessing its products for fair value. In anticipation of the new regulation, we had already developed concepts for assessment tools and frameworks for their application. As a result, we could focus immediately on tailoring an assessment framework that was right for OSB – a bespoke approach that characterises our risk and regulation practice.

In further work, we helped OSB ensure that the way it planned to map customer journeys and track customer outcomes was robust. “Being able to support OSB in driving an end-to-end focus on customer outcomes and being able to evidence good outcomes for customers in practice was vital,” says Wayman. She continued, “putting customers at the heart of the business, acting to deliver good outcomes, and preventing harm are the key to truly embedding the Duty.”

As the final deadline approached, we continued to work closely with OSB to independently assess the success of their implementation programme for open products in July 2023, and developing their approach to regular board reporting on the success of that programme and the delivery of the requirements for closed products ahead of the July 2024 deadline.

Driving radical change and cultural renewal

Our work means OSB can be confident of complying with the new Consumer Duty and of knowing the bank’s reputation is secure. The radical change in regulation has also created an opportunity to build a new customer-centric culture that will strengthen the bank’s positioning as a champion for underserved customers.