Two years into Consumer Duty, most firms have the policies. What the FCA increasingly asks for is the trail: can you show, client by client, that good outcomes were considered, acted on, and recorded at the time?
Almost every firm now has a Consumer Duty framework document. Far fewer can pull up a specific client and show the thread: what was known, what was recommended, why it was fair value for that person, and what happened next. The Duty is judged at the level of outcomes, and outcomes live in the day-to-day record — emails, file notes, review letters, the follow-up that did or didn't happen.
That's uncomfortable, because the day-to-day record is exactly where busy firms are weakest. The work gets done; the trail is patchy.
When files are sampled, the questions are practical:
None of this demands new documents. It demands that the documents and messages you already produce are findable, dated, and attached to the right client.
The firms that handle this well share three habits.
They record at the moment of the work, not after. A file note written the same day is evidence; a reconstruction six months later during a file check is a liability. Anything that turns the day's emails and meetings into the record automatically — rather than as a Friday admin task — compounds over a year into a defensible file.
They keep the reasoning, not just the outcome. "Switched to fund X" is a fact. "Switched to fund X because charges fell and the client's capacity for loss reduced after retirement" is evidence. The rationale is usually in an email or a meeting — the discipline is making sure it lands on the file.
They can search their own history. Most Consumer Duty questions are answered somewhere in the firm's correspondence. The difference between a good afternoon and a bad week is whether you can find it.
No tool makes a judgement Consumer Duty–compliant. What software can do is remove the friction between doing the work and evidencing it: filing correspondence against the client automatically, logging actions with timestamps, surfacing the history when a reviewer asks. If the evidencing happens as a by-product of the work, it actually happens.
One caution: if client data leaves your firm to make that possible, you have traded one regulatory question for another. Ask any vendor where processing happens and who can see the data. The best answer for a small firm is usually: on your own machine.
Orchestrator runs on your machine, drafts in your tone, and keeps a record of everything. Free 7-day trial, no card required.
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