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Consumer Duty & compliance

Evidence that stands up — call by call

The Consumer Duty expects firms to monitor and evidence good outcomes across their whole customer base. COSA doesn't make you compliant on its own — it gives your people the coverage and the evidence to show that you are.
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  • PRIN 2A · the Consumer Duty
  • FG22/5 · Duty guidance
  • FG21/1 · vulnerable customers
  • SM&CR · reasonable steps
  • Equity Release Council Standards

The four outcomes

What COSA checks — and the evidence you keep

Your rules define what good looks like for each outcome. COSA checks every call against them and keeps the proof.

  1. Outcome 1 · PRIN 2A.3

    Products & services

    COSA checksRecommendations are anchored to the needs and objectives the client described in their own words.

    You keepThe client's objectives, quoted, alongside the rule verdict.

  2. Outcome 2 · PRIN 2A.4

    Price & value

    COSA checksFees, charges and long-term costs — such as interest roll-up — were explained, not assumed.

    You keepThe passage where each cost was explained, with the verdict and its reasoning.

  3. Outcome 3 · PRIN 2A.5

    Consumer understanding

    COSA checksKey risks and features were covered, and the client showed they followed.

    You keepVerdicts on each required topic, with any gaps flagged for review.

  4. Outcome 4 · PRIN 2A.6

    Consumer support

    COSA checksSigns of vulnerability were noticed and the adviser adapted — pace, support, third parties.

    You keepVulnerability flags, the adviser's response, and the reviewer's decision.

Vulnerable customers

Every customer's circumstances, noticed

The FCA's guidance on the fair treatment of vulnerable customers (FG21/1) groups drivers of vulnerability into health, life events, resilience and capability. COSA listens for all four across the whole call — then assesses whether the adviser responded appropriately.
  • Signs judged in context, not by keyword
  • Whether the adviser adapted — pace, support, involving others
  • Flags routed to review, with the evidence attached

Vulnerability signals

FG21/1 drivers
  • Health“I get muddled with numbers since my stroke.”
  • Life events“Since my husband passed in March…”
  • Resilience“We're behind on a couple of bills.”
  • CapabilitySon answering questions on his mother's behalf
Each signal is judged in context — including whether the adviser noticed and adapted. Answers to a lender's health questionnaire aren't treated as signs on their own.

Evidence

Findings a supervisor can follow

Every verdict carries a written explanation, the quoted evidence and a confidence score. Overrides by authorised reviewers are recorded next to the original verdict — nothing is silently changed.

Detailed rule results

9/12 passed
  • Call recording disclosure givenPassed
  • Vulnerability identified and handled2 EvidenceNeeds review

    The client disclosed a recent bereavement. The adviser acknowledged it but continued without checking they were comfortable to proceed or offering to involve a family member.

    I've not slept properly since my husband passed in March.

    Client · 05:26 · Fact Find, 24 Sep 2026

    Confidence
    High
  • Interest roll-up explainedPassed
  • Independent legal advice recommendedFailed

Coverage

Monitoring you can account for

Sampling leaves you explaining what you didn't hear. With COSA, every in-scope call is assessed and every excluded call is logged with its reason — so you can show exactly what your monitoring covered, and why.
Assessed
1,284
every in-scope call
Not analysed
72
each with a reason

Not analysed, last 30 days

Call selection: Active
  • Shorter than your minimum42
  • Voicemail18
  • Not a monitored adviser7
  • Call type not assessed5

Beyond the Duty

Support for the rest of your regulatory picture

    • SM&CR
    • Reasonable steps

    Senior Managers & Certification Regime

    Senior managers must take reasonable steps to oversee their areas. COSA gives you complete coverage, MI on outcomes and trends, and a record of every review and override.

    • DISP
    • File reviews

    Record keeping, complaints and file reviews

    Recordings become searchable transcripts with the assessment attached. When a complaint or file review lands, the client's whole history exports as one pack.

    • MCOB 8
    • ERC Standards

    Equity release advice

    Encode the standards your advisers follow — independent legal advice, family involvement, roll-up explained — as rules checked on every relevant call.

    • MCOB
    • ICOBS
    • COBS

    Your conduct rules, whatever the product

    Mortgage, protection, insurance or investment calls: write rules for the disclosures and conduct your sector requires, scoped to the call types they apply to.

A tool for your oversight, not a substitute for it

COSA's assessments support professional compliance review; they aren't regulatory advice or a compliance decision. Findings should be verified against the recording before action is taken — which is why the quote, the reasoning and the call recording sit side by side.

Show your supervisor every call, not a sample

See how COSA would evidence the outcomes your firm is accountable for — using calls like yours.

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