Consumer Duty: why your evidence is only as good as your data
The Duty didn't change what good advice is. It changed what you have to be able to show — and that turns out to be a data problem long before it's a compliance one.
A quick recap of the four outcomes
The Consumer Duty asks firms to deliver — and to demonstrate — good outcomes across four areas. Products and services should be designed for an identified target market and sold to it. Price and value should be reasonable relative to the benefit a client actually receives. Consumer understanding means communications that genuinely land, tested rather than assumed. And consumer support should help clients act in their interests without unreasonable friction, with particular care for those in vulnerable circumstances.
None of that is new in spirit. What is new is the regulator's emphasis on evidence: a firm is expected to monitor outcomes and be able to produce the record that shows it did. Saying you treated a client fairly is no longer enough. You have to be able to point to where that fairness is written down.
Why scattered tools make evidence fragile
Most firms didn't set out to fragment their data — it happened one sensible purchase at a time. A CRM here, a cashflow tool there, a separate suitability writer, a spreadsheet for fee reviews, a portal with its own login. Each is fine alone. The problem is that the evidence for a single outcome now lives in pieces across all of them.
When a price-and-value assessment sits in one spreadsheet, the fee history in the CRM, and the suitability rationale in a Word document on a shared drive, you don't have a record — you have a reconstruction project. And reconstructions are where things go wrong. The version you open isn't the version that was sent. The date on the file isn't the date of the decision. The figure in the letter doesn't match the figure in the system because one of them was updated and the other wasn't. Under scrutiny, those small inconsistencies are exactly what undermine an otherwise sound piece of advice.
What “good” actually looks like
Defensible evidence has three properties. It is singular — there is one record of what happened, not several competing copies. It is timestamped — you can show not just what was decided but when, and what the client saw at that moment. And it is traceable — the conclusion in the suitability letter connects back to the fact-find, the objectives, the risk profile and the costs that produced it, without anyone having to take it on faith.
When those three hold, evidence stops being something you assemble after the fact and becomes a by-product of doing the work properly. The audit trail writes itself because every action touches the same underlying record.
Practical tips
A few habits help regardless of the tools you use. Decide once, in one place — capture the rationale at the point of the decision rather than writing it up later from memory. Date everything, including the version of any communication the client actually received. Make your MI fall out of the data rather than being typed up separately, so the numbers in your board pack are the same numbers in your live records. And treat vulnerability as a flag on the record, not a note in someone's inbox, so the right care follows the client through every interaction.
The underlying point
Consumer Duty rewards firms whose data is coherent and punishes those whose data is scattered — almost regardless of how good the advice was. That's the principle Bloom is built around: one client record that the fact-find, cashflow, suitability report, fee review and portal all read from, so the evidence is timestamped and traceable by default. The compliance benefit is real, but it's really just what happens when the data is right.
See how Bloom keeps your Consumer Duty evidence in one place →