Consumer duty, A WHO2 view

Aug 24

2 min read

THE WHO2 GLOBAL VIEW

The FCA has published its latest findings on good and poor practice across products and services under Consumer Duty.

And for us at WHO2, one message stands out:

Having the process is not the same as proving the outcome.

The FCA’s review looked at 38 firms across financial services, including insurance, and identified good practice alongside clear areas for improvement.

The findings cover product design, target markets, ongoing monitoring, distribution, third parties and customers in vulnerable circumstances.

SOME OF THE KEY THEMES?

Target markets need to be sufficiently granular, not generic descriptions that simply tick a governance box
Customer outcome MI needs to go beyond complaints. The absence of complaints does not, by itself, prove good outcomes.
Firms should use data to identify emerging issues and trigger targeted, risk-driven reviews.
When firms make changes to products, services or customer journeys, they should validate whether those interventions actually improved customer outcomes.
Manufacturers and distributors need clear structures for sharing information and
understanding what is happening across the distribution chain.

This is exactly why we believe product governance needs to be a living, evidence-led

process, not an annual assessment that sits in a folder.

Through Benchmarq360, WHO2 works with insurance businesses to independently assess how products, processes, distribution, data and customer outcomes operate in the real world identifying gaps, opportunities and areas where stronger evidence or action may be needed and how it’s evidenced through, BenchmarqIQ.

THE QUESTION SHOULDN'T JUST BE:

"Do we have the right process?"

It should be:

"Can we evidence that is delivering the right outcome, and do we know quickly enough when it isn't?"

That is a much harder question.

And, increasingly, it's the one that matters.

The views expressed in this article are those of WHO2 Global Ltd and do not constitute professional advice. All content is for informational purposes only.