Are digital channels ready for the Consumer Duty?

What does the Financial Conduct Authority (FCA)’s report on its review of firms’ progress with their Consumer Duty implementation plans tell us about the readiness of digital channels?

The opinions expressed here are those of the authors. They do not necessarily reflect the views or positions of UK Finance or its members.

The FCA recently published its review of the implementation plans of larger ‘fixed’ firms that have a dedicated supervision team at the regulator.

While it found evidence of progress and cited examples of good practice, it also found that: ”…some plans that suggested firms may have considered the requirements superficially or are over-confident that their existing policies and processes will be adequate.” (Consumer Duty implementation plans | FCA)

Customer-centricity and a great customer experience (CX) make good business sense at any time, but with the arrival of the Consumer Duty and the increased level of scrutiny from the FCA, CX isn’t just good business sense – it is becoming a regulatory imperative.

Any thought that firms could meet the new requirements by just using existing data has been dispelled by the report which makes clear that firms need to think deeper about the type and granularity of the data they are planning to monitor: ”…In some cases, firms’ data strategies seemed to be largely based on repackaging existing data…” This is particularly relevant for digital channels.(link)  

The Consumer Duty expects firms to seek deeper understanding and insight into their customers digital experiences (and other channels) to know if they are achieving good outcomes by:

  • recording and replaying digital sessions.
  • retaining important sessions for as long as required to investigate complaints or disputes.
  • monitoring every session and triggering alerts for individual sessions or cohorts which are struggling and need additional help and support – especially vulnerable customers.
  • capturing behavioural insights which highlight where journeys or information need to be modified.
  • using Voice of Customer to link feedback from the website to individual sessions and identify other customers experiencing the same issues but who didn’t leave feedback.
  • undertaking Root Cause Analysis to identify whether issues are down to technology, software, devices, user actions, content, journeys – whatever the cause and resolve it.
  • collecting CX to monitor friction points to ensure they are achieving the intended outcome.
  • using A/B testing to optimise the effectiveness of customer journeys.
  • analysing complaints to identify issues which are impacting customer outcomes.
  • undertaking past business reviews to determine whether redress is required.

Digital Experience Intelligence platforms give firms the capabilities:

  • to capture the data required to test and evidence that customers are getting good outcomes.
  • to monitor all activity and provide the insights and alerts when customers may be struggling and need additional help and support.

And best of all, the solution is fast to deploy.

For more from Glassbox, a Digital Experience Intelligence platform, on the Consumer Duty visit its website blog.