With eyes firmly on the calendar for the new Consumer Duty Regulations coming into force in July 2023, many companies may think they have it covered……

“It’s just an extension to TCF rules, right?” WRONG

Consumer Duty is so much more. It is about putting the consumer at the same level of importance as the owners and shareholder.

How many companies can truly say they have the right culture, accountability and governance in place to comply to the new regs?

Here are our top 5 tips:

1. Change the culture within your organisation towards consumer complaints
Is it a case of guilty until proven innocent? Too often there a culture of cynicism towards the consumer and belief they are not being truthful. How much training is given to your staff to change this culture?

2. Make it easy to ask questions or raise a compliant
Do you make it hard to complain? No email address on your website? Call centre only open certain hours? Make it so hard and long winded that people give up, thinking they will try again tomorrow ………. My friend recently spent over 2 hours the phone to a well-known internet provider on behalf of their 74 year-old mother-in-law (Netflix & Amazon being her only use) who had been charged for the premium fastest speed broad band (suitable only really for an FX dealer working from home) at their ‘standard rate’ having come out of her term with them over 4 years ago with no notification to her of any better deal or package for her.
Do you consider the less techno minded consumers?

And then……….. they offered a refund only for the past 12 months of over charging……..and then…….. tried to take it off her bill each month rather than pay her the refund for the full amount as had been promised.

3. Be accountable
Hold your hands up when you have made a mistake. Stick to your SLAs. If you say you are going to resolve a complaint within a certain number of days, you should. Or at least, do you then proactively tell the consumer there is a delay and the ETA or is it up to them to have to remember to get in touch? Could this be seen as yet another delay tactic?
Stick to promises made with regards to refunds and resolutions.

4. Re-evaluate if the product or service remains appropriate for the consumer.
At the time of onboarding the consumer, the product or service may have been right, but what processes and controls do you have in place to ensure that it remains so at renewal time? It is not good enough under consumer duty to solely place the onus on them to realise and to take action.

5. And lastly but very importantly – Put consumers first when designing product or tech changes
When designing a new product, do you seek consumer feedback at the start of the process?
Do you engage with your consumer base? Do you ask them what they want/need from you? Do you ask for feedback? Do you learn from it?
In my experience, companies put Internal operational efficiency first above customer needs and wants.

The FCA have published information for firms here

1RS are risk and compliance experts who have the knowledge and software solutions to meet the needs of your consumers and your organisation to be compliant to consumer duty.

Contact us for a demo, to see how we could help you.

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