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Consumer Duty

Ensuring we deliver good customer outcomes.

The Financial Conduct Authority’s new Consumer Duty will set higher and clearer standards of consumer protection across financial services and require firms to put their customers’ needs first.

Published in July 2022, the Consumer Duty goes further than the Treating Customers Fairly (TCF) framework by requiring FCA regulated firms to ‘act to deliver good customer outcomes’. 

The Consumer Duty rules relate to four outcomes that represent critical elements of the firm-consumer relationship, which are instrumental in helping to drive good outcomes for customers:

  • Customer Understanding: Customers receive communications they can understand.
  • Products and Services: Customers receive products and services that meet their needs.
  • Consumer Support: Customers get the support they need, when they need it.
  • Price and Value: Customers receive products and services that offer value.

What we're doing

We put the customer at the heart of everything we do and already have well-established frameworks embedded into our business which adhere to existing regulatory requirements.

We’ve carried out a thorough analysis of the Consumer Duty requirements and have identified some areas of focus. Although we’re unable to provide direct guidance on Consumer Duty, we hope that sharing our approach with you supports your own activities:

  • We've defined what 'good' outcomes look like for our customers
  •  We've conducted an extensive gap analysis between the FCA requirements and what we’re currently doing. The good news is that we’re already meeting the ‘Products & Services’ and ‘Price & Value’ outcomes due to previous regulations (fair pricing, Insurance Distribution Directive and Product Governance Sourcebook (PROD) – see our distributor product guides).
  • We've noted some gaps relating to ‘Customer Understanding’ and ‘Customer Support’ and this is where our focus lies.
  • We've identified which documents, communications and journeys need to be tested with customers to ensure we deliver good outcomes. We aim to have completed this by the deadline at end of July.
  • In parallel to the testing, we’ll be making improvements based on any research findings and are enhancing our continuous improvement programme to ensure that we continue to deliver against the customer outcomes.
This applies to all end customers including individuals, SMEs and larger corporations.
All communications that are created by Allianz for the end customer are being reviewed. If the document is marked ‘for intermediary use only,’ this is out-of-scope.
The intermediary is responsible for the communications they create themselves and share with the end customer.
We’ll be working with a 3rd party agency, who are experts in behavioural economics. They will be conducting an audit of all our documents, communications and journeys, and will be identifying any areas where the customer may not understand our communications. The audit will be followed by a testing programme with a panel of commercial customers.
We’re not expecting a need to request any data or additional information from our brokers. However, we do welcome any feedback or suggestions.
We’ll be working with a 3rd party agency, who are experts in behavioural economics. They will be conducting an audit of all our documents, communications and journeys, and will be identifying any areas where the customer may not understand our communications. The audit will be followed by a testing programme via a combination of surveys and interviews with a panel of commercial customers.
We’ll be including vulnerable customers in our communications testing programme to make sure we understand how best to meet their needs. We continue to deliver against our vulnerable customer standard which outlines our commitment to recognise, understand and respond to vulnerability and the needs of vulnerable customers.
At Allianz we already have well-established frameworks embedded into our business. We’ve conducted an extensive gap analysis between the FCA requirements and what we’re currently doing. We’re already meeting the ‘Products & Services’ and ‘Price & Value’ outcomes due to previous regulations (fair pricing, Product Governance Sourcebook (PROD) and the Insurance Distribution Directive). We’ve noted some gaps relating to ‘Customer Understanding’ and ‘Customer Support’. We’ll achieve compliance through our robust communications testing and implementation programme.
We aim to test all high priority items by end of July. This includes communications whereby customers need to take an action or make a decision.

More information

Full details of the new Consumer Duty can be found via: 

FCA Website
Information for firms
consumer duty podcasts
Product Oversight and Governance
Information on Allianz’s approach to the Product Oversight and Governance rules for brokers.

 
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The fair treatment of
vulnerable customers 
Find out more on the steps we’re taking and how we can work together to ensure customers experiencing vulnerabilities receive the additional support they need to engage with our products and services.
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