5 crucial areas to improve to be Consumer Duty compliant

Written on
byNicola Wee
A woman sitting cross-legged thinking about her credit score which an indicator shows to be poor

With the cost of living crisis pushing more and more people into financial vulnerability, the FCA is putting renewed pressure on lenders to provide the best possible service and support for their customers.

Their recent ‘Dear CEO’ letter written to over 3,500 lenders urged financial institutions to act now and provide the necessary help to customers who may find themselves in financial difficulty, reminding them of their duties and putting additional focus on customers that may be considered vulnerable. 

The final guidance of the FCA’s Consumer Duty proposals was published on 28th July, and enforces controls on firms to ensure they are providing good outcomes for their customers, putting even more pressure on them to update their processes and make sure they remain compliant with the new guidelines. 

But what does this mean practically for Consumer Lending companies? There are 5 critical areas which your business you should be focusing on to ensure you’re Consumer Duty compliant.

1. Quality Assurance and oversight

Whereas previously a typical process would have seen around 1-3% of customer interactions being monitored, with a typical focus on processes and agent performance, there will now be a significant increase in coverage required with a primary focus on fair customer outcomes. Rather than a ‘box ticking’ exercise, this will form a huge part of prioritisation, triage and escalation procedures for customers.

2. Agent conduct and coaching

Although you may already have induction and training programmes in place with semi-regular agent coaching sessions performed in-house, there will be an expectation to provide live/near live assessments of agent conduct and performance, with automated assessments of mandatory statement or process adherence. Training will be linked directly to performance and customer outcomes, ensuring improvements are made and adhered to.

3. Executive oversight

Currently, we’re used to seeing summary KPI reporting at Board level and Executive Committees, with very little involvement or understanding at an individual level. The introduction of the new Consumer Duty guidance means there will be an expectation for executive teams to demonstrate a greater degree of involvement and understanding when it comes to customer processes, controls and escalation.  The Board and Executive Committees will not just have to understand the number of complaints but importantly, the reasons behind them, what remedial action was taken and was it effective.

4. Complaints management

While complaints management procedures are almost definitely already in place, with each complaint followed up, resolved and reported, we are now going to see a greater focus on demonstrating that all complaints and expressions of dissatisfaction have been appropriately captured and recorded. The FCA will be looking for evidence of how complaints feature in product and service development.  Currently, consumer lenders log official complaints made by customers but there will be a large number of customers who are unhappy with the product or service, may have articulated that to a customer service representative but didn’t lodge a formal complaint. It’s these important interactions that require a means of identification and monitoring for process, service and product improvement.  

5. Vulnerable customers

Vulnerable customers have always been a key focus for any Consumer Lending company, however previously this was mostly dealt with at the beginning of a customer’s journey, with pre-sale suitability assessments, staff training, vulnerability registration and access to support services. In future, the FCA wants to see evidence of ongoing monitoring of customers, with the ability to identify, record and respond to their changing circumstances and continually review the suitability of the products and services they have access to.


Depressed young woman having bad headache holding her temples feeling stressed by lack of money to pay out family debts, her puzzled husband standing next to her, trying to come up with solution


One of the key tools that can help your business ensure it’s Consumer Duty compliant is speech driven QA automation. 

Speech monitoring software gives you a huge amount of control over your customer interactions, ensuring your customers receive a consistent and positive experience regardless of whether they’re speaking directly with you, or an outsourced third party (such as a call centre). 

Aveni’s platform captures every customer interaction, analysing it to provide the insight you need to reach a high level of compliance, as well as excellent customer experiences and agent performance.

Find out more about Aveni Detect

If you’re interested in finding out more about how Aveni Detect can help your business and for a demo on how it works, get in touch to find out more. 

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