Change Catalyst - Consumer Duty’s challenges and opportunities

Financial Advisory

23 November 2023

Advisory DistributorsCommunicationConsumer DutyESGFinancial AdvisoryvalueVulnerable client

Expert: Tom Hawkins, Head of Strategic Partnerships, Charles Stanley Facilitator: Ben Wright, Director of Progress, Change Squared Ltd


Key concerns and uncertainties - The main concerns raised were around attracting new clients, political uncertainty affecting markets and investments, and interpreting regulatory expectations correctly. There was uncertainty around how intrusive and granular the FCA will get in assessing firms’ implementation.

  1. Opportunities from the Consumer Duty - The new regulations were also seen as an opportunity to review and improve internal processes. Firms felt Consumer Duty had provided helpful focus and a catalyst for positive change in culture, controls and communications.
  2. Delivering and demonstrating value - Understanding value from the client’s perspective was discussed extensively, with insights shared from recent research. Key elements highlighted were the importance of trust, relationship, and tailored service over investment performance initially.

The discussion covered various topics around Consumer Duty implementation, including key concerns, opportunities, client perceptions of value, vulnerable clients, avoiding foreseeable harm, data usage, culture change, regulatory uncertainty, ESG investing, and the importance of service differentiation. The group shared insights into their experiences adapting to the new regulations, communicating with clients in more engaging ways, and working collaboratively as an industry to raise standards.

There was acknowledgement of the challenges but also optimism about the Consumer Duty driving positive outcomes. The debate highlighted the increased accountability across the value chain, the need for robust processes to demonstrate suitability and value, and the importance of ethics and consumer-focused culture in delivering good client experiences.

Key takeaways:

  • Review client communication mediums and segmentation to tailor messaging appropriately
  • Assess vulnerable client numbers and classification robustness
  • Consider implementing more engaging communication formats like video and personalised content
  • Evaluate advice processes to ensure demonstration of value is captured sufficiently
  • Review centralised investment propositions to identify opportunities for greater customisation and differentiated servicing
  • Discuss collaborating with industry peers to share insights and promote best practice standards
  • Plan regulatory horizon scanning agenda to monitor expectations, especially around vulnerable consumers