The dawn of a new era – embedding Consumer Duty into BAU

When the FCA published its final guidance on the new Consumer Duty just over a year ago, few firms would have fully grasped the scale and scope of work needed to hit today’s implementation deadline, in order to evidence that they are providing good outcomes for consumers against the FCA’s four key pillars.

A man reads his investment literature

Customer Understanding – a core foundation 

For many of the firms that we work with, the Consumer Understanding outcome has been a particular focus. As something that has been at the core of The Wisdom Council’s purpose since we were founded over a decade ago, it will come as no surprise to anyone that we have already had a busy year and see no sign of that abating. 

Over the past six months, we’ve tested and evaluated more than 200 documents, such as KiiDs, factsheets, exit letters and brochures, as well as numerous additional web pages and digital communications across all stages of the client journey. More than 1000 customers and proxy customers have contributed to over 600 hours of interviews, workshops and online communities. These customers have shared their insights and, sometimes, frustration about the way the industry talks to them. Many of these insight projects have landed ahead of today, specifically to allow firms to make critical improvements and draw up action plans before the deadline.   

"It’s very open and friendly but then suddenly becomes more technical and maybe there should be a bit of a graduation because after that lovely, friendly introduction, suddenly all these terms came at me."

Your next areas of Consumer Duty focus

Firms have been resolutely trying to get a handle on what is expected of them, and only over the coming months will the regulator determine whether they’ve done enough. So is it time to take the rest of the summer off? Not quite. In reality, now is the time to take a step back and ensure that anything learnt so far is being embedded in the daily experience of customers.

Rather than being the finish line, today is the start of a new regulatory regime. We are already seeing this reflected in plans for the remainder of the year and into 2024.

Firms are looking to consolidate learning; set up systematic training programmes for staff to ensure that any insight is widely shared and becomes the new normal; build on early testing; and to look well beyond that first phase of implementation.

In our experience, the questions that firms are now grappling with are:

  • How do you draw the customer voice in to strategy and planning?
  • How does what you have learnt so far impact product development, operational enhancements, digital strategies, distribution arrangements?
  • Are your products genuinely targeted at the right customers through the right channels?

Helping you to embed understanding into your comms

As we gather our findings from our tranche of recent research, more than ever we have a clear focus on what the industry needs to do to improve how it communicates with customers. Ensuring that documents are clear, relevant, accessible and complete may sound easy, but we have found that some customers have scored as low as one or two out of five on documents. In fact, six out of 10 documents related to fees and charges were given a score of two out of five.

We’ll be releasing a white paper in the coming weeks to showcase our findings. If you’re mulling over the questions above, The Wisdom Council is here to support you – we have just the evidence we need.

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The Wisdom Council

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