Working notes from the FairLedger team on Consumer Duty evidencing for UK payments and e-money firms.
Price & value and products & services are the outcomes the FCA can test with numbers. Here is why most payments firms answer them manually — and what a defensible alternative looks like.
Margin-based, benchmark-based and outcome-based fair-value calculations each have a place. This is when each one is the right answer for a UK payment institution.
The pack a Consumer Duty Champion needs is not the pack most vendors ship. A note on structure, appendices and the read that survives an FCA question.
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