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Consumer Duty will influence a necessary rethink over how we communicate – Wilson

by: Stuart Wilson, chairman of Air Club
  • 17/07/2023
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Consumer Duty will influence a necessary rethink over how we communicate – Wilson
Watch Prime Minister’s Questions or indeed Question Time any week, and you’ll be able to see firsthand why there is such a huge debate in politics right now about the language politicians use and the potential harm it can cause.

At its worst, we’re talking about rhetoric which demonises or incites hatred, but even if political discourse doesn’t hit these terrible heights, the use of certain language has the chance to cause harm. 

On the flip side, language also has the potential to inspire, to cut through complex matters, to change lives, and I certainly feel like this potential exists within financial services, specifically the importance of language within the later life advice space. 

At Air’s recent National Later Life Adviser Conference, I spoke about language and its importance within the advice process, specifically within the context of the forthcoming Consumer Duty rules. 

  

Acting as translators 

For what it’s worth, I tend to think those active in the later life advice space are some of the best in terms of turning complex concepts and themes into simple, easy to understand advice and recommendations. 

I often think of advisers as translators in that sense – weighing up customer wants and needs against product features and choice, and turning those into solutions that deliver exactly what their clients need.  

It is no easy task, particularly in a space where clients might have potential vulnerabilities, or reduced capacity, or where they might have difficulty understanding financial matters. Or indeed, where they might have had little engagement with their finances, perhaps leaving it to a partner who is no longer there to manage them. 

So, I believe that many later life advisers are at the top of their game in this regard, but what we can also say is that there is always room for improvement. And, we might add, that Consumer Duty is going to demand that this improvement is made, that it is evidenced, and that advisers can show exactly what has changed, why they changed and the positives it delivered to their customer base. 

Even for later life advisers – who I believe, as mentioned, are some of the very best in the profession at using the right language for simplification, explanation, etc – Consumer Duty provides the important opportunity to test this theory, and to improve it. 

  

Test the effectiveness of your comms 

For example, one of central tenets of the Duty in my opinion, is walking in the customer’s shoes, putting yourself in their position, and then determining just how customer-friendly your process is and whether it truly delivers the positive outcomes the Financial Conduct Authority (FCA) is expecting. 

To test this, why not either put yourself through your process, from initial customer engagement or contact, right through to completion and post-completion care? Or perhaps even better, put a relative or friend through it and secure their feedback on their understanding, what they didn’t get, where they struggled, what the pinch points might have been, and how they would have improved it. 

Essentially, it’s the parent/grandparent test. Would you be comfortable if your mum or grandmother went through your process? I guarantee that, while you might be close to 100 per cent confident, there will be some issues encountered that you might not have even thought of as being issues. 

It may be the way you explain a concept or product. Your email/letter communication might not be as clear as you thought. You might be leaving it too late after completion to contact a customer, or you might not offer a product or service that your client believes you should. Little things that, if left unchecked, might turn into bigger issues and might contribute to a less than positive experience or outcome for the client. 

Smoothing off these potential edges, and very importantly, documenting what you have done, is likely to help fulfil your own Consumer Duty responsibilities.  

It will also deliver a greater likelihood of a fully-satisfied customer who totally understands what they are signing up to, why you’re recommended this product/service, and what it will do for them as a result of that advice.  

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