Consumer Duty

The FCA emphasises the importance of recording customer calls to meet Consumer Duty requirements

3 min read

In the FCA’s recent Consumer Duty Retail Lending webinar, Jonathan Phelan, Head of Department, Consumer Finance at the FCA urged firms to record customer interactions as a critical step in being able to monitor and evidence customer understanding – a key part of the Consumer Duty measures.


He explains, “…I’d put the next one in capitals: keep a record of what you have said to [customers]. If it’s a face-to-face relationship, don’t just walk out, it’s not the end of the relationship. If there’s a complaint, if there’s a problem later, if the customer is going to later say ‘I didn’t understand the risk of default and what would happen,’ you need to have a record of that.


“The other thing I would write down in absolutely bigger, bolder capital letters is monitor the outcomes. Because you might try communicating with customers in different ways over time […] test those outcomes. Work out if more customers default if communicated in one way than if they were communicated to in another.”


The importance of Phelan’s message comes into sharp focus in a recent article by The FT Adviser where it reports 18% of advisors’ clients have called to cancel or reduce their protection cover due to the cost of living crisis.  Advisers and advice firms have several responsibilities under Consumer Duty, they need to:

  • be confident that consumers understand the risks of reducing their cover
  • provide consumers with cover they need and can afford to keep them protected 
  • prove customers understood the terms of their cover and any penalties when they purchased it
  • make it as easy for customers to switch, cancel or complain as it as for them to purchase the cover in the first place


The ability to prove customer understanding can really only be achieved if advisers have a record of what was said at the time. This serves two valuable purposes: 1) firms can test different messaging and channels to see which are most effective and continually improve the way customers are communicated to, and 2) should a customer complain there’ll be evidence in place to show how the terms of the product or service was explained to them at the time (appropriately or not).


Recording calls has clear benefits from a consumer understanding perspective but the value doesn’t end there. By pairing up recording calls with the ability to intelligently monitor and analyse them, organisations can unlock value across multiple areas: 


Improved risk assurance through greater coverage. Using speech analytics platforms such as Aveni Detect, firms can monitor and analyse every customer interaction to pick up on risks such as complaints, expressions of dissatisfaction, customer vulnerability and agent conduct.


Manage Consumer Duty by providing the regulator with evidence through improved MI and deeper insights and analysis into both consumer and agent behaviour. Firms can use these insights to improve customer understanding, identify vulnerability and the factors that lead to better customer outcomes.   


Raise agent/adviser performance by offering more engaging, personalised coaching experiences. Understand the factors that constitute a skilful and successful conversation and help teams raise their level using these insights. 


Drive quality assurance efficiency through speech driven automation. Machine assess each call, rank them for risks and triage the highest priority calls to human assessors for review. Auto-complete quality assurance assessments straight from the voice of the customer to drive greater efficiencies. 


For organisations that don’t record calls currently open themselves up to much greater risk and will be unable to provide the evidence requested by the regulator to prove aspects of Consumer Duty compliance. For organisations that do record customer interactions, the next step is to use technology to harness this wealth of insights to meet not only Consumer Duty expectations but also unlock opportunity across the business, from improvements in product and service development to elevating customer service, agent performance and more.


Learn more about how technology can help you mitigate Consumer Duty risks.     


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