088: Preparing for the New Consumer Duty with Tim Chadwick - PIB Group

What is the FCA’s Consumer Duty and how will it affect you and your business? How much work will it take to meet the requirements of the duty? When do these changes need to be implemented, and how should you prepare for them? In this episode of the Insurance Broker Podcast, we are thrilled to be speaking with Tim Chadwick Group Chief Risk Officer at the PIB Group. In conversation with Boston Tullis’ Sarah Myerscough, he discusses the wide-reaching nature of the new duty, which could necessitate a substantial revision of various aspects of financial services firms’ operations. Having determined that, broadly speaking, client satisfaction and protection within the industry is inadequate, the FCA’s new regulation demands a new approach to the consumer journey which protects clients at every stage of their interaction with a financial services firm, including after the purchase of a product. As such, it is essential that brokers understand what the new Duty requires of them.   Quote of the Episode “In a nutshell, what the regulator is really looking for firms to do is to put themselves in the customer’s shoes and to make sure that they're focused on good customer outcomes, and really importantly, that it's part of their firm's culture. So, this isn't some box-ticking exercise. There are very clear expectations around culture and, importantly, around the role of the board in all of this.” Throughout the episode, Tim asserts that the Consumer Duty is not merely a superficial administrative exercise. Rather, it reflects a concerted effort on behalf of the FCA to transition from a consideration of customer satisfaction within financial services as a matter of box-ticking to a responsibility embedded in the culture and practices of a given firm. A protection of the customer at all levels must therefore be interwoven through the fabric of the organisation. For some businesses this may require a few tweaks, while for others it may necessitate a systematic restructuring of practices.   Key Takeaways Most brokers always work in the best interests of their clients. While the FCA recognizes this, they also acknowledge that some firms within the wider financial services sector fail to implement sufficient strategies for the protection and wellbeing of their customers. Some products and services are either not fit for purpose, or ill-suited to their ostensible target market. Furthermore, some products arguably fail to deliver fair value to customers. In 2020, the FCA conducted a Financial Lives survey, which found that only 35% of financial services firms were deemed to be honest and transparent in their dealings with clients. As such, the Consumer Duty aims to usher in higher standards of customer support, to ensure that their needs are always attended to by firms, particularly if they are vulnerable, and that ultimately, positive customer outcomes are secured. While this notion is not entirely unprecedented, the Duty develops on regulations already in place by focusing more on positive outcomes for customers and imposing a clear responsibility upon firms to evidence that they are consistently achieving these outcomes. The duty is a series of measures which orbit around a central principle, being that firms must demonstrate that they can deliver good outcomes for retail clients (both individual and commercial). This notion, Tim explains, is underpinned by three cross-cutting rules: Firms must act in good faith, addressing the imbalance in knowledge and expertise between themselves and clients Firms must identify areas of foreseeable harm and curtail them Firms must enable and support customers in pursuing their financial objectives by providing them with appropriate and accurate information and advice Tim subsequently outlines four outcomes associated with the consumer duty, explaining in detail the FCA’s guidance about how firms should conduct themselves. To hear his advice, listen to the episode today! The deadline for implement