REGULATORY EXPERTISE
6 . How do you adapt your communications to meet the needs of customers with characteristics of vulnerability , and how do you know these adaptions are effective ? Advisers should discuss key features of documents , allowing clients to ask questions and take steps to confirm understanding whilst clients should be engaged enough to replay key information throughout . There should be support in place to aid customers with their understanding of key documentation . This may include making reasonable adjustments to support their needs e . g ., offering family / friend meetings or facilitating contact through communication channels that suit the client . Any adaptations should be recorded , with steps taken to adjust service . These can mitigate harm and empower the customer to engage in the advice process .
7 . What assessment have you made about whether your customer support is meeting the needs of customers with characteristics of vulnerability ? What data , MI and customer feedback is being used to support this assessment ? The firm should consider different client groups within its client bank and likely prevalence of the four key drivers of vulnerability , for example , younger clients = financial resilience : older clients = health and life events . The firm should assess if there is a particular group of customers within its target market likely to have characteristics of vulnerability . An up-to-date and personalised vulnerable person ’ s policy should be in place and kept under review . Adaptations to the advice process to support the needs of a vulnerable customers and a record of these steps can be maintained on file or using available technology . Client feedback is again essential as to whether the needs of clients and fair value are being met . Internally , there should be ongoing discussion around the issue of vulnerability , making use of third-party support to educate staff .
8 . How have you satisfied yourself that the quality and availability of any post-sale support you have is as good as your pre-sale support ? Primarily file checks should be carried out in line with firm ’ s Training and Competence Plan , where a file review results in an unclear or unsuitable outcome , the firm takes steps to address this both with the affected client and with the adviser . This is recorded and considered in respect of the advisers T & C Plan and Fit and Proper assessments . Where the firm offers different tiers of service , this is kept under review by the adviser and a client can change dependent on needs . The firm should have a process for clients that do not engage with an ongoing service for which they are paying , and these outcomes are analysed . Firms should ensure advisers are accessible , clients are in an informed position around how to cancel or switch an ongoing service , they understand how to complain and there is a record of any pro-bono support you may offer as part of your service .
POST IMPLEMENTATION , AN ANNUAL CONSUMER DUTY REPORT SHOULD BE SIGNED OFF BY THE FIRM ’ S MANAGEMENT AND MADE AVAILABLE TO THE FCA IF REQUESTED . THE REPORT CONTAINS DETAILS OF THE FIRMS ’ MONITORING AND ACTIONS AND HOW THE FIRM IS PERFORMING IN RESPECT OF EACH ASPECT .
9 . Do individuals throughout your firm – including those in control and support functions – understand their role and responsibility in delivering the duty ? The Consumer Duty should be at the centre of the firm ’ s ethos going forward with a top-down approach . The firm could hold staff meetings to discuss the Consumer Duty and its impact and expectations . Good quality records should be maintained , and all client interactions documented , ideally with use of a back-office system is used to record client contact and actions , whilst any trends / concerns are identified . Post implementation , an annual Consumer Duty report should be signed off by the firm ’ s management and made available to the FCA if requested . The report contains details of the firms ’ monitoring and actions and how the firm is performing in respect of each aspect .
10 . Have you identified the key risks to your ability to deliver good outcomes to customers and put appropriate mitigants in place ? There are many risks within a financial planning firm to not delivering good client outcomes and it is managements responsibility to ensure due diligence is undertaken on an initial and continuing basis , so client outcomes are monitored and that clients are in receipt of the level of service that is expected . In terms of costs , charges should reflect the complexity and demands of the service provided and the price the consumer pays should be reflective of the value they receive . The firm should review its charging structure , whilst checking and obtaining evidence that the client understands what they are paying , how they pay and what they receive in return .
To keep up to date with all the latest regulatory change , and support from SimplyBiz and Compliance First , on Consumer Duty , visit the dedicated Hub in the Compliance area of our websites .
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