4 October 2023
‘A new Consumer Duty’: new access rules for financial services organisations
Since July of this year, financial services organisations have been expected to follow new rules that govern how they should treat their customers, especially more vulnerable customers. If you are an organisation that offers financial services such as banking, insurance or investment, this is for you.
We want to help you keep up to date and explain how A2i can help you meet the needs of your customers.
The Financial Conduct Authority’s policy statement ‘A new Consumer Duty’, discusses how financial services organisations need to better care for their customers by providing flexible support. Financial services organisations need to make sure customers can make well informed, confident decisions about their finances. The rules that fall under this new policy have been effective since 31 July 2023.
A new Consumer Duty
The Duty is made up of 4 outcomes:
- Fair value
- Suitability and treatment
One of the four outcomes of The Duty is Access – this means that diverse consumer needs are met. One of the ways suggested to improve access is to offer customers more channels of support. Channels of support are the different ways services are available to help customers, such as by telephone, email, in person, on webchat, or video call.
Channels of Support
The FCA acknowledges that some channels of support may be unsuitable for vulnerable customers or customers with protected characteristics. Within the policy statement, the FCA give an example of how these individuals needs should be met, ‘some customers may find it difficult to take in information provided over the phone and have a need for written communications.’
By law, reasonable adjustments are to be made for disabled customers under the Equality Act 2010. Otherwise, a product or service may not be accessible to certain individuals. This might mean your company offers alternative formats such as Braille, Audio, Large Print, or Easy Read. The provision of alternative formats could be the difference between someone paying their household bills, or getting into financial difficulties.
Fair treatment of vulnerable customers
The FCA also produced guidance for financial service organisations to accompany ‘A new Consumer Duty’, called ‘the fair treatment of vulnerable customers.’ Within this guidance, the FCA suggests actions to promote the fair treatment of customers such as ‘holding focus groups with customers with characteristics of vulnerability.’ It is important to talk to people with lived experience and to listen to what they need. Coproduction will ensure that your organisation’s efforts to become more accessible are validated by people with disabilities.
Simple and effective communication
The guidance also talks about using simple and effective communication. Easy Read, as an alternative format, uses simple and easy to understand language instead of jargon and technical industry terminology. A2i can produce documents such as financial statements and legal documents into Easy Read booklets that are accessible to customers with learning disabilities.
When communicating with customers, your organisation should look out for signs and phrases which could indicate that someone is struggling to make payments or understand letters or telephone conversations. The FCA suggests that vulnerable customers may use phrases such as ‘I hate these press buttons’ or ‘I can’t read my bill’. When hearing these phrases, staff members should offer customers alternative formats or channels of support.
How A2i can help you
We hope that our brief overview of the Financial Conduct Authority’s policy statement will urge organisations to read more and make genuine changes to their products and services.
A2i are always happy to help organisations learn more about alternative formats and to suggest who might benefit from them. We understand many financial services organisations will want to offer alternative formats as soon as they become aware of a customer’s specific needs. A2i are more than happy to offer transcription services on an ad hoc basis, as and when you need. Our minimum turnaround is 3 days, but we will do our best to accommodate your deadline.