What happened?
Speaking at the CISI/Financial Planning Conference 2022, the FCA’s Chief Operating Officer and Executive Director, Emily Sheppard, described the regulator as moving towards becoming a more innovative, assertive and adaptive organisation driven by outcomes. TCC Associate Director Neil Dethick used this as the starting point to consider the consumer support outcome, the fourth and final outcome in TCC’s Consumer Duty deep-dive series.
Support must be available throughout the customer journey, whether by phone, email, in-branch or webchat. The FCA does not prescribe which channels firms should use, but expects firms to demonstrate that they provide effective support for customers’ needs.
Why does it matter?
Neil explains that firms need to consider two key points when deciding what support to offer: first, that the channels available meet the needs of the customer, and second, that where a product is designed for a specific market, firms are explicit about which support channels are available and whether they suit everyone. The FCA cites a poor practice example of a customer unable to read braille or large print who continued to receive paper communications despite requesting email.
Customer needs can also change over time, for example following a change in financial circumstances that affects how a customer can access support. Where this happens, the FCA expects firms to adapt their support accordingly, including helping the customer exit the product if appropriate.
Who is affected?
This applies across wealth management and financial advice, pensions and retirement income, payments and fintech, banking, consumer credit and lending, general insurance and protection, and motor finance, wherever firms provide ongoing support to customers.
Key risks
- Support channels that do not meet the needs of customers with specific requirements
- Failing to make reasonable adjustments for disabled customers under the Equality Act 2010
- Not adapting support when a customer’s circumstances change, such as losing mobile access
- Insufficient support for customers struggling with payments during the cost-of-living crisis
Recommendations
The FCA wrote to 3,500 lenders reminding them of the standards expected to support customers through the cost-of-living crisis, and indicated it will build on these standards under the Consumer Duty. Sheldon Mills, the FCA’s Executive Director of Consumers and Competition, said the regulator expects all firms to get the basics right and provide good quality support, with early action for those struggling with debt.
Supporting sources
Frequently asked questions
Does the FCA prescribe which support channels firms must offer?
No; the FCA does not prescribe which channels are most suitable, but expects firms to demonstrate they provide effective support for customer needs.
What should firms do if a customer's circumstances change?
The FCA expects firms to be adaptive and flexible, adjusting support and, where appropriate, helping the customer exit the product.
How many lenders did the FCA write to about the cost-of-living crisis?
The FCA wrote to 3,500 lenders reminding them of the standards expected to support customers.
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