Embedding Consumer Duty with Nottingham Building Society

After achieving Day 1 compliance with the FCA’s Consumer Duty regulations, a “Day 2” delivery was required to further embed Consumer Duty within the society, to ensure continued and sustainable regulatory alignment.

Nottingham Building Society engaged deploy12 to review and lead the programme.

The Challenge 
By July 2023, the Society had made significant progress toward achieving Day 1 compliance with the FCA’s Consumer Duty regulations, supported by their advisory partner. With strong foundations in place, the next phase of work focused on deepening and embedding the regulatory, cultural, and operational changes required for sustained compliance. To support this transition from advisory input to practical execution, the Society sought a delivery-focused partner that could build momentum, provide assurance throughout the implementation, and enable the senior leadership team to refocus their time and attention on broader strategic priorities.

This included replacing an illustrative plan with a realistic, actionable programme, coordinating internal and external stakeholders, and ensuring the Society met further obligations ahead of the regulator’s expectations.

The Solution 
deploy12 was engaged to lead the “Day 2” delivery of the Society’s Consumer Duty Programme, including a review of existing collateral, definition of a clear and agreed scope, and replacing the illustrative roadmap with a “do-able” delivery plan, underpinned by strong governance.

Working in close collaboration with internal teams and second-line risk, deploy12 supported the Society in establishing a delivery structure that provided clear and consistent assurance to the Programme Steering Group (the PSG), the Society’s Risk Committees, and the Executive. The enhanced programme governance approach, combined with a focus on reducing the critical path, helped strengthen operational confidence across the organisation. This was evidenced by the programme’s stability and the absence of change requests to the Steering Group. Executive engagement was streamlined from daily involvement to a structured monthly steering meeting and optional weekly check-ins, reflecting increased trust in delivery momentum, control and accelerated completion of business outcomes.

As the programme concluded, deploy12 conducted a final Health-Check, contributing insights into the Society’s internal Change Excellence initiative and supporting a smooth, sustainable handover of ongoing compliance activity into business-as-usual operations.

The Result 
The programme’s “doable plan” delivered 48 Level 0 and Level 1 milestones by August 2023:

• 22 milestones ahead of schedule
• 22 delivered on time
• 4 minor, non-critical delays (due to reallocation of internal resources onto other business priorities)

The programme closed on 1st March 2024, five months ahead of the Society’s original illustrative plan.

Although the Consumer Duty Programme was not designed to generate direct financial returns, it delivered substantial long-term value through a range of non-financial outcomes that strengthened the Society’s operational and cultural foundation. These included:

• Enhanced regulatory and legal confidence through further reduction of compliance risk
• Sustainable compliance fully embedded into business-as-usual operations
• A proactive, customer-first culture aligned with Consumer Duty principles
• A further strengthening of governance and assurance, supported by second-line oversight, ensuring sustainable regulatory alignment

Reflecting on the impact of the engagement following its successful completion, Sue Hayes, CEO, shared the following perspective:

“deploy12 were instrumental in filling gaps in our change delivery capability. They delivered the detailed consumer duty plan, which they supported fully the delivery of, and web-replatforming programs ahead of schedule. They provided high-quality resources for analysis, design, planning and testing across our change portfolio and lots of appropriate challenge on the reality of delivery. Their straightforward communication and quality services have set us up for further success. They aren’t the cheapest, but you get what you pay for. I would recommend the people who worked with us highly!”

And following the conclusion of the project, Paul Howley, CTTO, offered this insight into the collaboration, value and outcomes delivered:

“I engaged deploy12 in 2023 to help accelerate our change portfolio.  They brought their skills to augment our delivery capability as well as their comprehensive Health-Check to highlight changes we needed to make in our journey to achieving change excellence. Their straight-talking approach is refreshing, and they provided high-quality resources for analysis, design, and testing across our change portfolio. deploy12 have been very helpful in positioning us for further success, and I’m delighted to recommend them”.