Under the new consumer duty regulations firms will have to demonstrate, through evidence, how they deliver good consumer outcomes. The move to a more data led approach has resulted in companies seeking ways to demonstrate this requirement for the board to review through an annual report which will be challenged by the consumer duty champion. In their quest there is a danger that too much focus is on an inside out approach. Quite simply the firm gathers data using their language, style, content and methodology as evidence of delivering good consumer outcomes. The consumer is involved in this process but their input is very much controlled.
Perhaps firms should be looking at an outside in approach where the customer is fully engaged and has a much more open role
Perhaps firms should be looking at an outside in approach where the customer is fully engaged and has a much more open role in whether a good consumer outcome was achieved and of course maintained. The desire to control the way in which the customer is engaged is partly driven by the fear of opening the doors to a torrent of complaints. But perhaps the answer lies in realising the better long-term results might be achieved after responding to some of the short term issues identified by consumers. The FCA tell us clearly in their success measures of the importance of complaints analysis and how they will be looking at matters. Analysing complaints from unexpected charges characteristics performance changes and service are amongst those indicated. Firms will be expected to step in and take action which could include removing products, changing them or the process to ensure that consumers confirm good outcomes. The process to get to the desired state will be alien to firms as it feels like you are encouraging people to complain. This was not the long term purpose. By involving and consulting customers in all stages of the product design, delivery and service firms will better understand the consumers viewpoints. This presentation looks into how we can best gather genuine customer feedback on how for firm’s evidence good consumer outcomes using an approach that allows the customer a much more open agenda referred to as outside in.
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