Steve Sullivan

Time to panic?

Steve Sullivan, Head of Regulatory Compliance, Contact Centre Panel

The FCA’s Consumer Duty regime is a big deal. It’s been a long time in consultation, review and preparation and if you are an FCA regulated firm and if you’re not already very familiar with what it means, then it’s probably time to start panicking!

However, it might be that you provide services to a financial services firm at some point along its customers’ journeys, or that you are in a customer-facing part of a financial services firm that tends to be the last involved in these big programmes of work. In which case, what do you need to know?

If that is the case, it will almost certainly pay dividends to take some time to read through the FCA’s documents and guidance, which you can do here. You don’t need to be an expert in it all, but it’s good to be able to put the customer contact tasks in a wider perspective of what’s trying to be achieved, which is “delivering good outcomes for retail customers”.

The Consumer Duty is broad in its scope. It naturally has a major focus on how B2C financial services products and services are designed. As well as the changes at executive level that need to be made to recognise the Consumer Duty’s demands. But – I hope – you don’t need to worry about that, because your colleagues or clients should already have that in hand. Where they might benefit from your help is in how firms communicate with customers and support them. This is where the contact centre and customer engagement teams’ detailed understanding of customers and their needs can really help.

1. Customer Communications
Even if you have no direct role in the creation and distribution of automated communications (letters, texts, emails, in-app notifications, etc.) you will have ‘from the horse’s mouth’ an understanding of how they are received, understood and acted upon. Previously firms were obliged to be “clear, fair and not misleading” in their communications. Now they need to be “understandable” to a whole range of customers, in a variety of circumstances, including those considered to be vulnerable.

This is likely to require:

  • An in-depth understanding of the target – and actual – consumer market for products.
  • An understanding of the terminology, styles and timings of communications which work best for different customers.
  • The ability to both test, learn and potentially segment communications by different customer profiles.

All of which you and your teams are perfectly placed to help with.

2. Training
Your teams are directly interacting with customers. To do this as well as the Consumer Duty will demand, your people will need the skills and tools to:

  • Identify different customer profiles and requirements.
  • Flexibly understand when customers display vulnerability.
  • Recognise that their role is most importantly about “delivering good outcomes”.

If you feel that this is not already the case, then you need to ensure that training, coaching tools and resources are made available to you. If all these elements are already in place, then now might be the time for you to start training the rest of your organisation on these vital skills and aptitudes!

If you’d like to discuss how you are facing up to the Consumer Duty’s customer management challenges, just drop us a line.