Mystery Shopping for FCA Compliance (Consumer Credit)

Mystery Shopping is a priceless tool already helping many UK businesses involved in the sale of consumer credit to achieve, maintain and document their compliance with Financial Conduct Authority regulations.

Mystery Shopping provides highly detailed feedback on actual interactions with staff, providing clear insights into what happens at the “coal face” of customer experience, and during those moments when needs are established, and advice and information are provided.

Following recent proposals and comments from the FCA (especially around the new Consumer Duty), two things are clear:

  1. FCA compliance is set to become far more demanding and onerous for regulated businesses.
  2. The value of Mystery Shopping in this context is going to increase dramatically.

(To discuss a Mystery Shopping programme for your organisation, call us now on 01392 984224. Alternatively, email us on or click here to book an initial discovery call with Paul Taylor, our Managing Director.)

The changing face of FCA Compliance

UK Financial Conduct Authority (FCA)

The new proposals will see much increased demands placed on consumer credit providers. They will create a (very significant) “duty of care” towards customers.

Credit brokers and providers (and even their suppliers) will need to take responsibility not just for providing accurate information, but also for customer service, and even for ensuring positive customer outcomes.

One key principle in the proposals is that businesses should treat customers as they (or their leaders) would wish to be treated.

There will be a responsibility to ensure that any products sold are “fit for purpose and offer fair value”, and that “communications and customer service enable consumers to make and act on well-informed decisions”.

The FCA says that good customer outcomes are going to need to become business objectives. Special care will need to be taken to ensure that vulnerable customers achieve the same outcomes as other customers. The regulator has acknowledged that, for many firms, this will demand a significant shift in culture and behaviour.

More rigorous enforcement

While the FCA’s requirements themselves look set to become far more burdensome (and potentially subjective), the regulator has also made it clear that it intends to take a far more “hard line” approach to cases of non-compliance.

CEO Nikhil Rathi has recently stated that the FCA will not hesitate to remove firms from their “regulatory perimeter” (remove licenses) in cases of non-compliance. There have already been clear signs that things have already begun to move in this direction.

For businesses involved in selling consumer credit, this situation of increasingly rigorous regulation seems to be one that’s very serious and deserves very close attention.

Paying serious attention to this situation could be critical to business success and survival.


Mystery Shopping can help you to achieve and maintain compliance with FCA rules on consumer credit.

Regulatory Compliance


Without clear detailed feedback on what happens during customer interactions, it’s impossible to reliably measure or monitor your compliance.

Mystery Shopping can “hold up a mirror” to show you a clear view of your current standards and practices. This clear view can then be compared against current FCA rules, and then also against the proposed principles, standards and (eventually) new rules as they come into force.

Mystery Shopping has always been most valuable (especially for compliance applications) when used on an ongoing basis.

But in view of the new proposals (with increased requirements for monitoring clear communication and customer service), ongoing Mystery Shopping is going to become a truly essential part of the compliance toolbox.


If you are considering using Mystery Shopping for compliance purposes, it’s essential that you receive a high quality service, so you obtain a reliable and accurate view on performance.

The most basic requirements are

  1. Realistic and believable “shopper” interactions (that remain a “mystery”), and
  2. Reports on those interactions that are designed to tell you what you need to know and are accurately completed.

Achieving these two things consistently isn’t easy – it requires high quality programme management and oversight.

How Mystery Shopping works

Interactions through all channels (in-person, telephone, online (email, live chat, video chat)) can be checked and tested. Typically, with Mystery Shopping for compliance, interactions are recorded, so there is a record (and evidence) of exactly what is said by staff. Recordings can be referred back to during training or other interventions, and the fact that this evidence is collected enables businesses to demonstrate the fact that they are examining their own performance thoroughly.

Performance results are normally delivered through reports which each cover an individual interaction or enquiry cycle. The reports contain questions about key compliance elements and contain scoring so that the level of compliance can be measured and compared across interactions, staff members, teams, regions and organisations.

Individual reports are accessible through an online reporting platform, along with dashboards containing useful tools to help you to explore and analyse your data, and identify where to focus your energy.

(To discuss a Mystery Shopping programme for your organisation please call us now on 01392 984224, email us on or click here to book an initial discovery call with Paul Taylor, our Managing Director.)


Why Customerwise?

At Customerwise we have a wealth of experience in providing Mystery Shopping services focused on FCA compliance for providers of consumer credit.

We work directly with car brands, car dealership groups, insurance brokers, and retailers offering consumer credit. We also work as a preferred partner with retail compliance experts Product Partnerships, providing a range of Mystery Shopping services to help them monitor and improve their clients’ compliance with FCA requirements, and control business risk.

Kaizen Action Plans – a compliance “game changer”

In addition to the output that clients rightly expect from a Mystery Shopping company (reliable, in-depth feedback based on realistic interactions), we provide clients with a unique tool to help them ensure and monitor their own compliance: Kaizen Action Plans.

SASSIE Kaizen Action Plans image shows how the SASSIE platform can help clients to act on mystery shopping feedback.

Kaizen is a special feature within our powerful online reporting platform, SASSIE. It helps clients to track, manage and record the resolution of issues (whether compliance-related and / or performance-related) all in one place – within the reporting platform itself.

Whenever specified issues are highlighted through a Mystery Shop interaction, Kaizen brings relevant stakeholders across the client business into a conversation, facilitates communication to resolve any issues, and then keeps a record of this resolution for future reference (e.g. to provide evidence to the FCA where action has been taken to address issues).

Kaizen helps to make Mystery Shopping programmes even more of a powerful tool for monitoring and improving compliance. It helps businesses to not just identify compliance issues, but also address them.

Customerwise is well proven and highly trusted provider of Mystery Shopping services for FCA compliance applications. We’d love to help your business to remain safe and secure in this environment of increasing regulation.

For an initial discussion about how Mystery Shopping could help your business to remain compliant and reduce risk, call 01392 984224 or email us on or click here to book an initial discovery call.