Fair Value Under the Microscope: What the FCA Really Expects From Your Assessment Framework

Is your firm's Fair Value Assessment actually fit for purpose — or is it a compliance exercise dressed up as consumer protection?

Since Consumer Duty came into full force, the FCA has been unequivocal: firms must be able to demonstrate that the price customers pay is reasonable relative to the benefit they receive. That is not a box-ticking exercise. It is a structured, evidenced, and regularly reviewed assessment — and the regulator is watching closely.

In this episode, we cut through the complexity and get into the mechanics of what a genuinely robust Fair Value Assessment looks like. Whether you are an MLRO, a compliance officer, a senior manager with Consumer Duty accountability, or a board member trying to understand what "good" looks like, this episode gives you the practical grounding you need.

We cover:

— What "fair value" actually means under the Consumer Duty framework and why it goes well beyond simply checking your pricing

— The four Consumer Duty outcomes and how Fair Value sits within the broader obligation to deliver good outcomes for retail customers

— The FCA's supervisory expectations, including findings from thematic reviews and what the regulator has said firms are consistently getting wrong

— What a proper Fair Value Assessment Framework must contain — from product scope and cost analysis through to customer segmentation, distribution chain accountability, and outcome monitoring

— How to structure your assessment workbook so it is defensible under scrutiny, auditable, and genuinely useful as a management tool rather than a document that sits on a shelf

— Common failure points: weak evidence bases, unsupported assumptions, failure to consider vulnerable customers, and the absence of meaningful management information to evidence ongoing value

— The governance and sign-off requirements that sit behind a compliant assessment, including board-level attestation and the role of the Consumer Duty Champion

— How frequently your framework needs to be reviewed and what should trigger an out-of-cycle reassessment

— Practical tips for embedding fair value thinking into product governance, pricing decisions, and distribution arrangements from the outset

We also explore what the FCA's enforcement trajectory tells us about where the regulatory risk lies for firms that treat Fair Value as an afterthought — and why personal accountability under SMCR means that getting this wrong is not just an organisational risk, it is a career risk.

This episode is essential listening if your firm:

— Has not reviewed its Fair Value Assessments since Consumer Duty implementation

— Is approaching an FCA supervisory visit or skilled person review

— Has received FCA feedback indicating concerns about product value or customer outcomes

— Is preparing its annual Consumer Duty board report and needs confidence that its fair value evidence base is solid

Resources mentioned in this episode:

Compliance Consultant's Fair Value Assessment Framework & Workbook is a ready-to-use, professionally structured toolkit built specifically for FCA-regulated firms. It combines a step-by-step assessment framework with a fully formatted workbook, enabling compliance teams to complete, evidence, and document their fair value obligations efficiently and to a standard that reflects current FCA expectations.

Visit complianceconsultant.org to find out more, or call us on 0800 689 0190.