Consumer Duty Hub

Our Approach

We have developed a comprehensive and robust assessment process which evaluates several aspects of our business to determine the value of our products. This analysis is used to ascertain whether a product delivers fair value for customers. We have defined the detailed outcomes across all niche lending areas. We have implemented consumer duty dashboards internally to allow us to fully understand what we deliver to our customers in each outcome area. This will then be used to allow the society along with external feedback to make improvements.

A Summary of our Assessments

We have assessed that:

• Our product range continues to meet the needs, characteristics, and objectives of customers in the identified target markets
• The intended distribution strategy remains appropriate for the target market
• Our products provide fair value to customers in the target market

Our assessments have considered the following:

• The range of features that the product provides, the quality of the product, the level of customer service that is provided and any other features that the product may offer
• We consider the needs, characteristics, and objectives of customers with characteristics of vulnerability at all stages of the design process for this product to ensure the product meets their needs. Our manual underwriting approach allows the DIP and underwriting team to satisfy any concerns that they have around the applicants understanding of what they are agreeing to.  We have in place a framework to achieve good outcomes for vulnerable customers
• This target market assessment matrix segments the target customers for the product, recognising their different needs to enable tailoring of the services provided when brokers and direct advice distribute the Product.
• The interest rates, fees and charges customers pay for the product, comparable market rates, advice fees paid to intermediaries and non-financial costs associated with operating the product
• We have developed a comprehensive and robust assessment process which evaluates several aspects of our business to determine the value of our mortgage product. This analysis is used to ascertain whether the product delivers fair value for customers.
• The mortgage pricing model takes into account the following inputs; proposed product price and fee, product tranche size, cost of funds, direct origination costs (adjusted by niche based on its operational complexity), Origination fees (PROC and MIG as applicable), wider operating costs, expected credit risk cost and risk-adjusted capital require (adjusted by lending category), plus assumptions around loan sizes and expected LTV distributions based on recent lending benchmarks.
• The assessment follows a detailed and robust product approval process which determines the outcome including market analysis, products been checked via the pricing model and intermediary feedback. Smart Money Feedback is also reviewed to help determine the correct outcome.
• The outcomes of the assessment process are presented to Mortgage Product Committee and Management Assets & Liabilities Committees for approval allowing for challenge and further Buckinghamshire Building Society is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Registration Number 206022 GEN0164-06/04/24 investigation before we sign-off the outcomes and share the summary of our assessment with you.
• Any limitations on the scope, features and service we provide

The assessments can be accessed and downloaded using the links below.

This information is intended for intermediary use only and should not be provided to customers.

Our Expectations of Distributors

In order to fulfil our obligations under the Consumer Duty we expect distributors to be responsible for meeting their obligations under Consumer Duty, whilst working with the society to deliver fair value and good outcomes for consumers.

Intermediaries should continue to comply with their obligations to ensure that they treat customers in vulnerable circumstances fairly.

Please contact our Intermediary Sales Team if you have any queries or require additional information from us.

Our Fair Value Assessment Forms, Intermediary Terms of Business and Mortgage Product Distribution Document are available here to download: