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.