The Consumer Duty requires extensive analysis and monitoring to protect customers.
The Consumer Duty regulations cover a wide range of financial products and services. This includes:
high street banking;
communicating with customers in debt;
insurance products;
wealth management;
pensions, and
savings.
How can firms meet these requirements?
Amplifi has been designed to address the requirements set out in the Consumer Duty.
Testing.
All communications must now be tested to see how intelligible they are.
Amplifi can do this at scale, quickly and efficiently.
PRIN 2A.5.10: a firm must: (a) test communications before communicating them to retail customers; and (b) regularly monitor the impact of the communications once they have been communicated, to identify whether they are supporting good outcomes for retail customers.
Tailoring.
All communications must now be tailored for the capability of the likely readers.
Amplifi can help editors to draft documents with different audiences in mind.
PRIN 2A.5.13: (1) A firm should adapt its communications to support retail customer understanding if it identifies that: (a) there are areas of common misunderstanding among retail customers; or (b) retail customers are not experiencing good outcomes, including particular groups of retail customers such as those with characteristics of vulnerability.
Simplify.
Hard-to-understand documents must be made as simple as possible.
Amplifi uses guided simplification, highlighting problematic phrases and suggesting alternatives.
PRIN 2A.5.3: (1) A firm must support retail customer understanding so that its communications:
(a) meet the information needs of retail customers;
(b) are likely to be understood by retail customers; and
(c) equip retail customers to make decisions that are effective, timely and properly informed.
(2) A firm must communicate information to retail customers in a way which is clear, fair and not misleading.
Reporting.
Firms must be able to evidence what they have done to comply with the regulations.
Amplifi provides senior managers and boards with a clear audit trail ready to report to the FCA.
PRIN 2A.8.4: At least annually, the governing body of a firm must:
(1) review and approve the firm’s report on the outcomes being received by retail customers;
(2) confirm whether it is satisfied that the firm is complying with its obligations
What about after the initial document review?
Once communications have been assessed and simplified, the outcomes need to be measured on an ongoing basis to mitigate the intelligibility risk [guidance 8.63].
Our easy-to-use management information for internal quality assurance and external reporting facilitates this too.