NIG approach to FCA Consumer Duty
Background
The Financial Conduct Authority (FCA) published its Policy Statement PS22/9 and Finalised Guidance FG22/5 in July 2022, and we summarised the Consumer Duty in February, see here.
NIG welcomes and supports the FCA’s drive to require firms to deliver good outcomes for retail customers, supported by the three cross-cutting rules to:
- act in good faith towards retail customers
- avoid foreseeable harm, and
- enable and support retail customers to pursue their financial objectives.
The Consumer Duty
The Consumer Duty rules relate to four different outcomes which represent the key elements of the relationship between companies and their customers:
- Products and services
- Price and value
- Consumer understanding
- Consumer support
The rules require companies to consider the needs of their customers and how they behave at every stage of the customer journey. They will mean that customers should receive communications they can understand, products and services that meet their needs, offer fair value, and the support they need, when they need it.
For further information on the FCA Consumer Duty, visit the FCA website here.
How we are preparing for the new rules
When the new rules were published last summer, we set up a Consumer Duty programme to understand and then deliver the necessary reviews and changes required ahead of the regulations coming into force on Monday 31st July. This has included reviewing our customer journeys, communications, products and management information. Specifically:
1. Products and services
We have our ongoing programme of Fair Value Assessments and the summarised output of these, with our Target Market Statements, are published for every product on nig.com. The results of these reviews will continue to feed into our assessments of customer understanding and future product changes.
2. Price and value
In our Fair Value Assessments we continue to assess the data gathered to ensure our customers are receiving financial fair value. All of our products passed our testing in the last 12 months.
3. Consumer understanding
Most of our documents are aimed at you, our broker partners, to ensure you can understand our products and match these to customer needs. However, the communications that are for customers, including policy wordings, summaries and notices of annual changes, will be regularly tested and reviewed to ensure that they are as clear and unambiguous as possible for the target market customers. We have no plans to change any products prior to 30th April 2023.
4. Consumer support
We have reviewed our journeys where customers interact with us directly, especially in claiming and complaining, to ensure these processes work for our customers.
Wherever we find aspects of our approach that would benefit from changes, these will be made.
Working with you
Because our products are distributed by brokers, it is important that we work together to achieve the goals of the Consumer Duty and ensure good outcomes for our mutual customers. We do not, at this stage, envisage requiring any information from you, but will keep you updated. Similarly, if you have any comments or suggestions relating to our products and how they work for our mutual customers, please let us know via your usual NIG contacts.