From my conversations with advisers, I see a real desire to fulfil this aim, but also an acceptance that we’re not going to get this right immediately.
This is an area where I believe that the industry will be seeking continuous improvement, both in the run-up to the implementation dates and beyond.
The fourth outcome is providing a level of support that meets consumers’ needs, with an enhanced focus on the needs of vulnerable clients, which is an area that the FCA has specifically highlighted we all focus on improving.
Meeting consumer needs is the outcome that the majority of my adviser contacts tell me they have cracked.
However, this is a significant step up from treating customers fairly and the Prod rules in making sure investment solutions meet the needs of one or more identifiable target markets.
It is an area where we all have to do better – not just to onboard clients, but to continue to service their financial needs effectively and efficiently, and articulate progress towards meeting those needs in a language they understand, avoiding jargon where possible.
Clear communication at retirement
Having said all of that, I was reading a report recently (a consumer and financial communications survey by Simplify Consulting) that told me 46 per cent of financial communications received by people are read very little, if at all, as they are hard to understand, contain too much jargon and do not indicate an immediately clear action.
Interestingly, many of these communications are aimed at those who are at or nearing retirement.
This indicates that perhaps the industry needs to improve further in how it engages with and informs this key demographic at a crucial stage in their lives.
In summary, in order for the consumer duty to make a real difference, the industry needs to work better together.
Initially, it is very encouraging that many firms have been coming together to share their hopes, fears and aspirations, and consider ways of more effectively realising the regulator’s ambitions and meeting consumers’ needs.
However, we need to ensure that this isn’t just a cosmetic fix and that we continue to improve and challenge ourselves to be better and to do better.
Therefore, it’s vitally important that we don’t view the consumer duty as a tick-box exercise and, again, there are excellent examples of this across the market.
One adviser I know has started to re-engineer their advice models by thinking about the services needed by different cohorts of clients and then unbundling certain services to meet those specific requirements.