CONSUMER DUTY
SUPPORT AND UPDATES FOR FINANCIAL ADVISERS
Overview
Consumer DutyThe introduction of Consumer Duty is part of the FCA’s ongoing efforts to further enhance consumer protection in financial services. Consumer Duty combines an overarching principle that a firm must act to deliver good outcomes for retail customers, with expected behaviours and a number of consumer outcomes financial firms must meet and be able to demonstrate, to ensure they are acting in the best interests of their customers.
At Curtis Banks it’s always been our mission to help our customers thrive in retirement by providing flexible products, innovative technology, and complementary services to meet their needs, whatever stage of their journeys with us, so the fundamentals of Consumer Duty are not new to us.
This page provides our financial advisers with an overview of what we are doing to evidence that Consumer Duty plays a fundamental role in our business, and when you can expect key documents to be available.
Financial advisers also have a key role to play in ensuring they meet the requirements of Consumer Duty, as you provide advice and recommendations to customers on financial products and services.
Four Outcomes
The ‘four outcomes’ provide rules and guidance for firms, setting more detailed expectations around key areas of the firm-customer relationship:
| Products and Services | Price and Value | Consumer Understanding | Consumer Support |
|---|---|---|---|
| Our products are designed to meet the needs of, and are distributed to, identified target markets. | Ensuring our products represent fair value throughout the product and customer lifecycle. | Our communications support and enable customers to make informed decisions. They are given the information they need, at the right time and are presented in a way they can understand. | We provide a level of support that meets customers’ needs, enables them to benefit from the products and services we provide and helps support them achieve their financial objectives. |
Cross Cutting Rules
Consumer Duty requires firms to put consumers at the heart of their business and focus on delivering good outcomes for customers. It also introduces a set of cross-cutting rules focusing on three key behaviours which require firms to:
- Act in good faith towards customers
- Avoid foreseeable harm to customers
- Enable and support customers to pursue their financial objectives
Key Dates and Deliverables
30 April 2023:
We completed the manufacturer reviews necessary to meet outcome rules for all existing open products and services. The results of these have been shared in our Target Market Documents (see below) to help financial advisers (distributors) meet their obligations and identify if and where any changes need to be made.
31 July 2023:
Meeting implementation deadline for new and existing products.
31 July 2024:
Meeting implementation deadline for closed products.
TARGET MARKET DOCUMENTS
Target Market documents are designed to ensure that our products are targeted and advised appropriately, to avoid offering unsuitable products to customers. By providing our advisers with clear and detailed Target Market documents, we can collectively ensure that our mutual clients have products that meet their needs and expectations.
Listed below are the Target Market documents for our current products:
Curtis Banks In The Press
Consumer DutyYou can find links to our press articles and commentary regarding Consumer Duty below:
- PRESS: Is Consumer Duty the ‘happily ever after’ of pensions?
Caitlin Southall considers the future of pensions in a new Consumer Duty world in Professional Adviser - PRESS: Pension dashboard delays contradict Consumer Duty
Caitlin Southall looks at the ongoing delays in delivering pension dashboards, and how this might contradict the new Consumer Duty regulations. Read more in Money Marketing. - PRESS: How Target Market Documents can help meet client needs and achieve good outcomes
Caitlin Southall speaks with Professional Paraplanner about the upcoming Consumer Duty regulations, focusing on Target Market Documents and how they can support good customer outcomes.
Vulnerable Customers
For information and support for customers experiencing vulnerability visit our dedicated web page.
Useful Links
The following links provide additional detail from the FCA on Consumer Duty:
Q&A's
A selection of questions & answers to the common questions we have received from advisers are included below:
Who should I contact if I have queries about Consumer Duty at Curtis Banks?
Please contact your local Business Development Manager who will be happy to discuss.
How have you tested your open products and services to meet the requirements of Consumer Duty?
We’ve completed a Product & Service and Price & Value assessment on each of our open products against the first two outcome rules. The details and results of which can be found in our Target Market documents (please see link above). Customer journey reviews have been carried out on key services both to identify improvements for Consumer Duty as well as further reaching proposition improvements. All customer touchpoints have been identified, recorded and reviewed against a centralised framework and Communication Standards Guide. Key customer communications are also being tested via external third parties. Any actions identified relating to the delivery of our Consumer Duty requirements will be made ahead of the 31 July deadline.
How often will the testing of your products and services be reassessed?
Assessments will be completed regularly with the frequency determined by:
- The number of customers in the product
- Whether the product is open to new business or closed
- Whether there are any events or proposed changes that could materially affect the potential risks to the target market
This could range from every year for products subject to any significant events or changes to every four or more years for closed products with very few customers and no significant events or proposed changes.
The introduction of our Customer Outcomes Forum will oversee the ongoing monitoring and review of customer outcomes on a regular basis. Additional customer journey and communication reviews can be triggered at any time should poor customer outcomes be identified, through regular monitoring and customer feedback.
How will you identify clients that do not fall within your target market for your products and services?
We will review new business on a regular basis to assess whether the product has been distributed in accordance with the information in the Target Market document. However, in line with FCA guidance, it remains the responsibility of each distributor to ensure that the relevant target market is followed, as they are best placed to consider client personal circumstances, needs, objectives, characteristics and suitability.
If we have concerns about plans distributed to clients that we believe are unsuitable, we will first contact the distributor to raise and discuss our concerns. We will not take further action until this discussion has taken place unless we feel there is significant potential for poor customer outcomes by delaying action.
What governance do you have to oversee Consumer Duty implementation within your company?
We have a dedicated Consumer Duty Executive level Steering Committee, who report into our Executive Committee and oversee the project. Further approval is provided by the Group Board with challenge from our Consumer Duty Non-Executive Director.
Will you provide Management Information on products and services assessments to distributors?
There are no FCA requirements to provide specific Management Information (MI) included in our assessments to distributors. If you require further information, please contact your local Business Development Manager who will be happy to discuss.