Regulatory and compliance · Compliance officer, in-house regulatory counsel, product owner
Review a product against the Consumer Duty outcomes
A firm has a retail savings product that has been sold unchanged for four years and an annual product review due next month. The review reads the product documents against each of the four outcomes and names what the firm cannot currently evidence.
- Agents
- Research, Compliance & Regulatory
- First draft
- An outcome-by-outcome review comes back from one run, ahead of the product governance meeting.
The problem
Step 01 of 05
Open a compliance matter
The product, its target market statement, the customer-facing documents and the last two governance packs go on one matter with the review date recorded.
Project Halcyon: SPA warranties and disclosure
Buy-side warranty review, disclosure analysis and cited due-diligence grid.
- Client
- Halcyon Bidco Ltd
- Reference
- WC-2026-0412
- Practice area
- Corporate / M&A
- Jurisdiction
- England and Wales
- Responsible partner
- E. Vance
No conflict check on file.Chat, on this matter
Compare warranties with the disclosure letter.
Three high-priority exceptions require action: the unregistered charge, the change-of-control right and the tribunal claim.
Send a message… (@ to mention tools)BalancedPrepare for- 25 Aug
Disclosure exceptions matrix
Chat
- 21 Aug
Disclosure exceptions matrix
Run · completed · 560 credits
- 18 Aug
Project Halcyon: Disclosure Letter
Document · indexed
- 16 Aug
Project Halcyon: Share Purchase Agreement
Document · indexed
- 4 Aug
Matter opened
Opened
Step 02 of 05
Run the outcome review
Prepare for: Work-Stream Memo. Each of the four outcomes is addressed separately, with the evidence on the file matched to it and the absence of evidence stated as an absence.
Agent
Jurisdiction
Prepare for
Deliver as
Instruction
What should the agent look for?Documents
Drop a contract, or pick one from the matter
Also on the matter
- Offer_letter_v3.pdf2 pages
- Staff_handbook_2025.docx61 pages
- Board_minute_14_Aug.pdf3 pages
Platform model · zero data retention · audit register onStep 03 of 05
Read the two weakest outcomes
Consumer understanding and consumer support carry the least evidence, with no record of testing whether customers understood the interest rate change process.
6 items need your confirmation14 authorities · Where we lookedSenior Associate Employment Contract: English Law Review
Summary
- 1.
Clause 9(c), non-competeHigh
The 12-month prohibition on working for any law firm anywhere in the UK, Ireland or EU, in any capacity, is almost certainly wider than reasonably necessary and therefore unlikely to be enforceable.
Tillman v Egon Zehnder Ltd [2019] UKSC 32 - 2.
Clause 11, data and monitoringHigh
Blanket contractual consent is not an adequate basis for general employment processing, special-category data or unrestricted monitoring.
UK GDPR, Arts 6 and 9 - 3.
Clause 4, holiday carry-overHigh
The unconditional five-day cap conflicts with mandatory carry-over rights where sickness, statutory leave or employer failure prevents leave being taken.
Working Time Regulations 1998, regs 13 to 13A
- 1.
Step 04 of 05
Look at the vulnerable customer position
The memo separates what the documents say about vulnerable customers from what the monitoring data would need to show, and asks for the data that has not been supplied.
Settle any of these and a refined run folds your answers into the memo.
- Does the firm intend the covenants to bite in Ireland and the EU, or only England and Wales?
- Is there a separate monitoring policy the contract should reference?
- Has the employee already given a written working-time opt-out?
Step 05 of 05
Give the board a paper
The findings are re-run as an Executive Brief for the product governance meeting, with the gaps ranked by regulatory exposure.
Agent
Jurisdiction
Prepare for
Deliver as
Instruction
What should the agent look for?Documents
Drop a contract, or pick one from the matter
Also on the matter
- Offer_letter_v3.pdf2 pages
- Staff_handbook_2025.docx61 pages
- Board_minute_14_Aug.pdf3 pages
Platform model · zero data retention · audit register on
What comes back
A document, not a transcript.
- Each of the four outcomes addressed separately, with the evidence on file matched against it.
- The two outcomes with the weakest evidence named first, and the specific record that is missing.
- A distinction between what the documents claim and what the monitoring data would have to show.
- An Executive Brief for the governance meeting with the gaps ranked by exposure.
What it does not do
- It does not certify compliance. It reports what the file evidences and what it does not.
- It does not analyse customer outcomes data, which has not been supplied and is named as needed.
- It does not contact the regulator or make a notification.