It’s quite scary to think that it’s already been nine months since the last Consumer Duty deadline came into force. From 31 July 2023, the FCA’s new legislation applied to all new products and services, and all existing products and services remaining open for renewal. With the industry still coming to terms with the new guidance, the next deadline is now fast approaching. From 31 July 2024, Consumer Duty will also apply to all closed products and services. So how ready is the industry for this?

Interpreting the guidance

Back in May 2023, we surveyed 778 brokers as part of our H1 2023 Mortgage Lender Benchmark. We wanted to know how they were feeling ahead of the last July deadline. The feedback was mixed. While most felt they were ready for Consumer Duty, almost a third told us they were either not ready or unsure. Brokers voiced concerns around the expectations surrounding the new legislation, with many craving more information and clarity around what meeting the legislation actually looks like.

The challenge for many seems to be interpreting Consumer Duty. Of course, the regulator hasn’t been as black and white as saying companies ‘must do this and must not do that’. But the FCA would say that their guidance has been significant enough for everyone to get their house in order. And surely, most financial services companies would genuinely want to do right by their customers anyway? So for most firms, Consumer Duty should be about evidencing the good practices they’re already adopting, rather than making wholesale process changes. Of course there will be odd exceptions who aren’t already doing the right things, but those companies would need a complete overhaul anyway.

The good and the not so good

In February, the FCA published examples of what companies are doing well and what they could do better (1). They said: “We welcome the improvements made by many firms to deliver better outcomes for their customers. However, some firms are lagging behind”. So like our Mortgage Lender Benchmark survey suggested, the results were mixed!

Let’s take a look at an example of good practice first. Under culture, governance and monitoring, the FCA say: “Some firms are paying more attention service level metrics for call abandonment rates, root-cause analysis of complaints and customer satisfaction surveys, taking action to improve standards”. Customer surveys are clearly a big plus point in the eyes of the regulator, also being commended in the areas of consumer understanding and consumer support.

But looking at culture, governance and monitoring again, the regulator has identified room for improvement. The FCA say they’ve seen firms: “Who need better data and monitoring strategies. Firms should not be complacent and assume that they can just repackage existing data. We want firms to think seriously about what information they need to really understand their customers’ outcomes and issues they may be facing”. It shouldn’t be surprising that the FCA say that knowing as much about your customers as possible is crucial for delivering good customer outcomes. In fact, they actually say that an example of good practice is companies who’ve developed new data and metrics to better understand their customers.

Summary

With the mixed results seen in our own survey and from the FCA itself, it’s difficult to say exactly how ready the industry is for the final deadline. But there will likely be different levels of preparedness. Companies should remember what the legislation is all about – being able to evidence that they’re delivering good customer outcomes. Those who can demonstrate that they genuinely understand their customers and act on their feedback will have the best chance of meeting Consumer Duty.

To find out how Smart Money People’s data can help you to evidence good customer outcomes, head to our Consumer Duty page.

(1) https://www.fca.org.uk/publications/good-and-poor-practice/consumer-duty-implementation-good-practice-and-areas-improvement