17 Aug 2022

  • Financial Services

A new Consumer Duty – time for action

The regulations for the FCA’s new Consumer Duty have been confirmed and the deadlines are approaching fast. Firms have 12 months to adhere to the package of measures, and just a few weeks to put plans in place. So, where do you begin?

The final rules and guidance for a new Consumer Duty have now been confirmed. The Financial Conduct Authority (FCA) is setting higher expectations for firms’ standards of care towards consumers.

Underlying the regulation is a new principle that requires firms to ‘act to deliver good outcomes to retail customers’.

The regulator insists that its new package will ‘drive a fundamental shift in industry mindset’ and a change in culture, requiring firms to put their customers’ needs first and stop harm before it happens.

The FCA is giving firms 12 months to meet the higher bar – that’s an extension to the previously proposed 9 months, but still not long. And, the regulator expects company boards to have plans in place to assess their competency against the new rules by October 2022.

You have 8 weeks to make your plan.. where do you begin?

We will assume that at this point you have established a working group responsible for ensuring that Consumer Duty is a business priority.

Hopefully you have included customer champions in that group – their perspective might be from risk and compliance, customer experience or user-centred design.

That’s important because a useful first step is qualitative user research. It’s critical to understanding how well you’re helping customers achieve good outcomes and where you aren’t. As the FCA puts it, it will help you put yourself in your customers shoes.

It will also help you to corral colleagues, inspire action, build momentum and alignment – first-hand exposure to user research is the secret sauce of cultural change.

But you’ll need to apply rigour to how you do this research. You’ll need to map your customer journeys and undertake research at key points across them.

You’ll also need to define what good looks like – things that you can test for in user research – and then choose methods that credibly assess your journeys against those criteria. For example you might look to test comprehension during a sales journey by using a post-task ‘quiz’ to probe people’s understanding.

This will give you an outside-in perspective of your customer journeys – how your customers experience them – rather than how your organisation has defined them.

Customer centric change

The FCA’s focus is resolutely on customer outcomes. For firms to address this effectively and create lasting change,  they will need to look at the root causes for why consumers are not getting the benefits or value they should expect.

Organisations should apply a customer centric lens to review, and potentially change, their process, governance and culture. And as painful as change tends to be, this is the right kind of change.

How we’re helping

We’re working with firms to respond to the Consumer Duty. Through this work, we’re not just helping them meet their new regulatory obligations, we’re using it as an opportunity to set them up so they can yield the wider benefits that customer centricity brings.

Get in touch to chat about how we can help you make those changes.

Learn more about A new Consumer Duty – time for action