Consumer Duty: How L&G and other firms are addressing the comms challenge

Mark Foran

By Mark Foran, Senior Associate Director, Harris Interactive, part of the Toluna group.

The clock is ticking towards 31 July, and any consumer-facing provider within the financial services sector must have the words ‘Consumer Duty’ as a key focus right now, pivoting on four pillars: products and services, price and value, consumer understanding and consumer support.

The sector has always been aware that consumers’ rights and wellbeing need to be at the forefront of strategies and communications.  Following on from initiatives such as Treating Customers Fairly, there is now an even sharper focus on mitigating potential harm and, in the FCA’s own words, ‘providing good customer outcomes’.  This sharper focus needs to be fully inclusive, encompassing the most financially savvy to the most vulnerable in the UK.

With 31 July a looming deadline, as recently as the end of January, the FCA observed that many firms are “behind in their planning, so there is a risk that they may struggle to apply the Duty effectively once the rules come into force”.  Firms must carry out their review before the end of the current implementation period and then on an ongoing basis.


The communications challenge

The deadline is only one consideration for the industry to be mindful of, as the specifics of what needs to be addressed by that date is the more strident challenge for providers.

Communications are at the forefront of the challenge from the point of view of sheer volume, variation of subject area and customer journey stages involved, jargon and small-print inherent to the sector and the fact that relationships can be so remote that communications are, in some cases, almost the entire relationship.

Addressing the Consumer Understanding outcome is key, needing to be clear, timely, encourage an informed decision and, most of all, avoid any risk of harm to the consumer. Firms can no longer rely on what was done in the past.

Following much consultation across the sector, we at Toluna and Harris Interactive have a clear picture that providers are committing considerable time and resource to address the requirement to test, monitor and adapt communications. Yet with sometimes thousands of individual documents and different types of communications (mail, email, SMS, complex packs, call centre scripts, etc.), the testing, analysis, commentary and reporting of each communication one-by-one would be prohibitively expensive in both cost and time.

Added to this, if all providers are carrying out their own testing programmes there would be a proliferation of metrics and measurements with little or no ability to benchmark, create norms or compare and contrast performance.

A more efficient and cost-sensitive approach would be for several providers being able to rapidly test multiple communications at once and in the same way as others do.


The solution: how some firms are addressing this through new insight approaches

An objective approach to assessment of communications is needed to prove validity and prevent providers being perceived or accused of ‘marking their own homework’.

Due to the objectivity and comparability required within sub-sectors, it is critical that many providers are taking the same view and approach, are able to access benchmarks, benefit from a consistent measurement of comms and have safety in numbers within an approach which delivers results rapidly and cost effectively.  The end-game should meet the sector’s appetite for a way of assessing communications which allows them to compare their own communications and against the wider industry.

Working with Toluna and Harris Interactive, firms such as Legal & General and Assurant are embracing a syndicated insights approach to addressing the Consumer Understanding outcome through robust consumer testing.

This mutualised approach provides the reporting and risk control framework to meet Consumer Duty expectations and offers several key benefits:

  • Mitigating risk by agreeing on an approach that meets the requirements of the regulation.
  • Working together to implement a gold standard approach.
  • Financial savings from sharing the design phase costs.
  • Taking part in post-July industry comms testing benchmarking.

Firms are already benefitting from the collaborative design phase of the programme:

  • Extensive qualitative research has provided a refreshed, in-depth understanding of what Consumer Understanding means.
  • This up-to-date understanding also means that the right comms testing questions are being asked going forward, based on customers’ information needs and what would help them achieve good understanding.
  • Firms are able to demonstrate that they are not relying on prior approaches based on previous requirements or assumptions around how existing communications need to be adapted.
  • The result of this will be templated quantitative questionnaires for each part of the sector, automated for heightened efficiency for all users – the templates have been carefully designed to include key performance indicators, but companies can also add their own key metrics for internal comparison.
  • The result is a comparable, rigorously designed, robust way of assessing communications and formulating comms strategy going forward, informed quickly and clearly by benchmarks and ‘at a glance’ outputs. This efficient and clear approach to assessment means that providers can tap into the solution to enable them to test priority communications ahead of 31 July and a BAU testing framework for beyond.

The syndicate is growing, with several potential new members currently in discussion about joining. Interested parties can register here to attend Toluna’s Consumer Duty Syndicate event on 21 March.


About Harris Interactive and Toluna:

Harris Interactive simplifies complex decisions with critical consumer intelligence. We set ourselves apart as we fuse sector expertise and award-winning research design with innovative tools and technology from our parent company Toluna. This combination delivers impactful insights that keep clients ahead of what’s next. Expert in all areas of research design, implementation, analysis, and reporting, Harris Interactive has particular strengths in customer experience, brand and new product development.

Toluna delivers real-time consumer insights at the speed of the on-demand economy. With a commitment to leading by technology innovation, Toluna revolutionises market research and empowers clients with the agility to instantly conduct quantitative and qualitative research. By combining global scale and local expertise with innovative digital solutions and award-winning research design, Toluna helps clients explore tomorrow, now.


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