As firms get to grips with implementing the new Consumer Duty, the “Consumer Support” outcome is raising a number of key considerations with firms asking questions such as:

• How do we understand and define the right levels of support required to meet our customers’ needs and objectives?
• How confident are we that there are no hidden barriers preventing our customers from accessing and making full use of their products and services?
• How easy is it for our customers to complain and is the complaints process visible through all available channels?
• Where our digital offering claims that customers can make contact at all times and receive the same levels of service, have we adequately assessed whether we can support this claim in practice and is it being accurately measured?

The overarching aim of the Consumer Duty principle is to achieve good outcomes for customers. The Consumer Support outcome is intended to ensure that firms apply the same standards to customer journeys before and after the customer has taken out the product or service.

While the majority of firms will already have good practices in place for providing the right levels of support for their customers, the introduction of the Consumer Duty will require a significant uplift to their current practices.

The Consumer Duty rules are arranged into groups around four outcomes, which represent key areas where the FCA considers that there is a significant risk of harm. This article considers the key issues which arise in relation to the “Consumer Support” outcome.

Providing the right level of support

From the initial concept and design of a product or service, firms need to consider, for each channel, how much support is needed to enable the customer to access and make full use of its features & benefits. 

The critical elements are the operations and people needed to support customers in pursuing their financial objectives on a day-to-day basis. Firms should always provide comprehensive training to staff and give them the right tools to be knowledgeable and aware of customer needs in relation to the products & services provided, especially those who may have characteristics of vulnerability. 

In a recent assessment of a sample of firms’ implementation plans for the new Consumer Duty, the FCA gave examples of good practices in relation to the consumer support outcome. These included identifying specific customer journeys where it was acknowledged that improvements could be made to the current levels of support, undertaking exercises on a regular basis to monitor the quality of support in place, and providing information to customers through their chosen channels in order to support good decision-making.

Making it easy for customers to complain

Complaints received from customers are an important barometer for a firm to identify whether a product or service is meeting the needs and objectives of its customers. Firms can use learnings to their advantage where there are poor outcomes, by identifying the root causes and taking the right steps to improve outcomes for all customers.

Where firms are applying the consumer support outcome for complaints, they should be objective and honestly assess whether it is easy for a customer to complain. This can be identified by shadowing each customer journey and using complaints data to understand and determine if there are any avoidable friction and/or unreasonable barriers that may be stopping customers from complaining.

Monitoring in practice

Whether a firm is reviewing its existing monitoring frameworks and the inputs/outputs or looking at ways to effectively monitor whether a new product or service is providing the right level of consumer support, it’s critical to refer back to the key objectives and how it will meet customer needs and achieve good outcomes. Firms need to consider how they can demonstrate that the support provided is enabling customers to make full use of their products and services. Where deficiencies in customer support are identified, firms need to show that they are taking the right level of action to address this.

A common example is where the customer journey leading to purchasing the product or service is given greater focus than customer journeys for servicing or making claims.

It’s important that firms consider all of the metrics available to them. This includes not just call waiting & resolution times, the level of customer queries, and complaint handling times but also looking beyond these traditional metrics to greater use of digital methods, social media, a forensic review of web chats (automated and manual responses), and abandonment reasons.

Next Steps

Firms should be well underway with their reviews and implementation activities to meet the requirements of the customer support outcome, demonstrating they will be able to comply with the July 2023 deadline for new products and services, before turning their attention to existing products and services.

If you would like to discuss the application of the consumer support outcome or require any assistance in relation to any of these issues, please contact our team. 

Authored by Nick Oxley.