The overarching principle of the Consumer Duty rules is that a firm must act to deliver “good outcomes” for retail customers.
There are three main rules –
1, Firms must act in good faith
2. They must enable and support retail customers to pursue their financial objectives
3. They must avoid causing foreseeable harm
The Regulator expects firms to view outcomes across four areas; design of products and services, price and value, consumer understanding and consumer support.
Wealth Wizards believes technology is going to be fundamental for advice firms to meet their obligations. Especially so for larger companies and firms growing their bank of clients, they need to feel confident that their processes are robust and consistent across the entire company.
Consumer understanding and consumer support are key. For advice firms to evidence that they are conforming to Consumer Duty principles, they must ensure consistency even in the subjective areas.
So, how can technology help?
Whilst supporting their clients through a digital process, Wealth Wizards identifies five ways that advice firms can adhere to the Consumer Duty principles.
1. Gathering relevant client information. By using a digital fact find, clients can be asked for all relevant information in a consistent, compliant way. By having clients fill in the online fact find themselves, the information collected is accurate, as it is completed in the client’s own words. This forms a sound basis on which to take the guidance/advice further. The information can be used to pre-populate other forms and areas of the advice process. All data collected during the process is relevant and used appropriately.
2. Successful identification of the client’s needs and goals. This is achieved by taking the client through a codified (automated) journey. Along the way, they’re asked questions about their current circumstances and key objectives; this establishes whether they will be best suited to guidance or advice via a consumer-led or adviser-led journey.
3. Delivering consistent advice and recommendations. The digital advice journey can be scripted to meet the individual firm’s financial advice policies. This ensures that the journey of every client is consistent, compliant, and personalised according to the individual’s needs. As the FCA review the guidance and advice boundary, the codification of the guidance journey ensures consistent, fair customer outcomes.
4. Ensuring the client understands the advice and recommendations being made. This is a core principle of Consumer Duty as it encourages proactive engagement leading to greater understanding and improved financial well-being. Offering the client a digital journey that serves applicable, digestible, jargon-free content equips both the firm and the client with an engaging, educational consistent, and compliant process.
By gamifying the digital journey, clients can learn through play. Input figures can be repeatedly changed so that the client can see first-hand the financial impact of increasing or decreasing their contributions. Playing with the tool increases understanding of and confidence in the advice/guidance process and the recommendations made.
5. Evidencing the process to good outcomes. Advice/guidance delivered digitally equips firms with a recorded, auditable ‘story’ of what has been advised and evidencing that they have done their utmost to deliver good client outcomes. At each review, the information is clearly recorded and can be talked through and added to as required.
Mark Kiddell, Chief Commercial Officer, Wealth Wizards, says: “Understanding the customer is how firms can ensure they and their clients know what a ‘good outcome’ should be. Technology gives advice firms a tool that not only improves client engagement and understanding but also gives evidence to the client that they can achieve their goals in the future.
“With a digital tool, advice firms can reach many more consumers than they otherwise would. This empowers them to help close the advice gap and improve the financial wellbeing of many more clients.”