These are just example answers to give you an idea of the kind of information/response the FCA is expecting from firms. This is a template only and you should ensure that the answers you give are reflective of how you have approached the Consumer Duty and comply with it on an ongoing basis.
We have not completed any product testing, as the products and services we offer have been used extensively over a period of time and are well established. We have not added any new products to our offering. We are satisfied that the products we offer meet the needs of the consumer within their target markets.
The MI that we review includes but is not limited to:
The reviews of our MI have not indicated that the products are delivering poor outcomes, and we are satisfied that they perform as would be reasonably expected.
We do not actively offer products which may cause harm to vulnerable customers. However, we acknowledge that if a customer’s circumstances change, and they develop characteristics of vulnerability, there is a risk that the product may no longer be suitable or could potentially cause harm to the customer. However, our staff receive training to identify vulnerable customers, and we have procedures in place to respond to and assist vulnerable customers. Where we identify any risk of harm, we act swiftly to mitigate these, based on the individual needs of the customer. Despite any additional support we provide, a customer’s vulnerability may persist, so we remain vigilant to this fact throughout the customer journey with us.
Our fair value assessments did not indicate our products, services or chosen distribution method affected our customers being able to receive fair value. We do not have a formal Product Governance Committee or forum. However, our Senior Managers hold regular meetings, during which our product governance and the output from our outcomes testing is reviewed. Any areas of concern are discussed, with appropriate action being agreed and monitored at Board level.
We consider a number of areas including:
We have conducted a review of all our written communications and have made revisions where necessary. This includes making sure that we are avoiding jargon, highlighting important policy information, (such as conditions and warranties) clearly and prominently, and advising customers that we can provide additional support if they are vulnerable. We have also reviewed our scripts to ensure that we are using clear, plain language, and providing customers with ample opportunities to ask questions. Our website has also been reviewed to ensure that it is clear and easy for our customers to navigate and understand. We do not run any financial promotions. However, should we do so in the future, we will ensure that they are clear, fair and not misleading.
We adapt our approach on an individual basis, based on the situation of the individual customer. Our staff are able to identify vulnerability and to respond to vulnerability on a case by case basis. This will include speaking more loudly, or slowly for example, or ensuring documentation is issued in large print. Where documents are usually sent by E-mail, we can send by post if necessary. Where we feel the customer is having difficulty understanding, our staff will take extra care to repeat information if necessary and ensure the customers’ understanding, before they commit to buying any product or service. If we feel that the customer’s decision making is impaired, staff are trained to refer this to senior staff for further assistance so an appropriate level of support can be provided to the customer. Where a customer is in financial difficulty, we will try to assist with an appropriate payment plan, or advise on whether premium reductions are available through amending cover. In all cases, we will ensure that the customer has the right level of protection and won’t simply cut cover to reduce cost. We will ensure that the customer has appropriate cover for their needs, while helping them reduce their costs. We have reviewed our letters and amended them to include an invitation for customers who are vulnerable to ask for additional support if required. We feel that although our staff take great care to identify and assist vulnerable customers, a vulnerability may not always be obvious to them, leading to a risk of harm to the customer. We have therefore made changes to our correspondence to inform our customers that we are here to help them, if they are vulnerable and encourage them to reach out to us to ensure we can protect them as much as possible.
We use our CRM to record vulnerable customers and monitor how we are responding. Additionally, the MI that we review includes but is not limited to:
