In this guide
9. Consumer duty and treating customers fairly
The Consumer Duty lays down the standard of care that all Financial Conduct Authority (FCA) authorised firms should give to their customers. How we treat customers is fundamental to our business. The Consumer Duty applies across all of a firm's regulated activities from high-level strategic planning to individual customer interactions. The FCA’s Principle 12 For Business states that a firm must act to deliver good outcomes for its customers. The FCA has set out its expected standards under Principle 12 and the corresponding sections of the FCA Handbook under PRIN2A.
The new Principle is supported by three cross-cutting rules which explain how firms should act to deliver good outcomes. The cross-cutting rules are as follows:
- Act in good faith toward retail customers
- Avoid causing foreseeable harm to retail customers.
- Enable and support retail customers to pursue their financial objectives.
There are four outcomes which set out more detailed expectations for firms in areas that represent the key elements of the firm-consumer relationship, focussing on:
- Products and Services.
- Price and Value.
- Customer Understanding; and
- Customer Support.
Treating Customers Fairly (“TCF”)
The obligations under the Consumer Duty impose higher standards than the previous TCF regime. However, TCF does detail a set of outcomes which remain relevant to us. The outcomes enable us to adhere to the three cross cutting rules and four consumer outcomes required by the Consumer Duty and are detailed below so that they can continue to be referenced:
Outcome 1: Consumers can be confident that they are dealing with firms where fair treatment of customers is central to the corporate culture.
Outcome 2: Products and services marketed are designed to meet the needs of identified consumer groups and are offered accordingly.
Outcome 3: Consumers are provided with clear information and are kept appropriately informed before, during and after the point of sale.
Outcome 4: Where consumers receive advice, the advice is suitable and takes account of their circumstances.
Outcome 5: Consumers are provided with products that perform as firms have led them to expect, and the associated service is both of an acceptable standard and as they have been led to expect.
Outcome 6: Consumers do not face unreasonable post-sale barriers imposed by firms to change product, switch provider, submit a claim or make a complaint
What it means to you
We seek to apply the following approaches as means of meeting the good customer outcomes:
Keep things simple - Communicate clearly and explain things in plain English. Help ensure customerss understand their obligations.
Keep things easy - Provide customers with a named contact at each stage of an application. Contact customers at a time to suit them. Provide regular updates.
Keep things personal - Treat each customer as an individual. Offer customers a choice of options based on their individual circumstances.
Keep things open - Listen to customers’ views. Answer any questions honestly. Deal with any problems quickly and fairly.
Keep things professional - Treat customers with courtesy and respect. Observe the highest standards of integrity and professional standards.
If you feel we have not met these outcomes and have treated, you unfairly then please let us know. You can find out further details on our customer information: Complaints sheet.