"The first step an adviser can take to ensure they are compliant online is to put themselves in the consumers’ position – how easy is it navigate your website?"
Although Consumer Duty regulation is now firmly in place, and advisers are working to ensure they are sitting comfortably in line with the new regulations, there are some areas that may have gone under the radar.
One such area is your online presence – websites in particular may have been overlooked by advisers, despite them playing a key role in ensuring customers understand the products and services available to them. Keeping these sites up to date in line with FCA standards will remain critical for financial professionals in this new Consumer Duty world.
What are the FCA requirements?
Websites are often the first port of call for consumers to gauge an understanding of the products available for their own financial needs, and maintaining a level of transparency is critical for firms to both support consumers and remain in line with the regulatory changes.
In the Final non-Handbook Guidance (FG22/5), it is highlighted in point 4.8 that firms working within financial services will have their websites scrutinised, indicating the importance of staying up to date with new regulations.
Chapter 8 of the Guidance notes that: “Consumers can only be expected to take responsibility where firms’ communications enable them to understand their products and services, their features and risks, and the implications of any decisions they must make.” (FG22/5 8.1)
Information, on pricing in particular, must be made clear to consumers on these sites to ensure an understanding of the products on offer. Meeting the Consumer Duty principle of consumer understanding requires that clients have a firm knowledge on pricing of the product that they are interested in, other products available, and the risks, features and implications of exactly what they are aiming to purchase or take out.
This is stated clearly in Principle 12 in the FCA final guidance, noting that that firms operating in this sector must: “Ensure they have sufficient understanding of customer behaviour […] to be able to demonstrate that the outcomes that would reasonably be expected are being achieved by those consumers” (FG22/5, 4.8)
Securing this understanding of consumer behaviour is essential for firms. Indeed, key areas of interest to consumers can be tracked through analysing content engagement and user traffic, which are useful tools to help financial professionals understand what consumers are searching for.
Measuring performance against these metrics is one solution listed by the FCA to tackle reporting activity on consumer behaviour. The FCA notes in point 7.50 that firms should use ‘operational data which might affect value such as an app or website outages or service call abandonment rates’ (FG22/5 7.50) to better understand consumer outcomes.
As an adviser, what can I do?
The first step an adviser can take to ensure they are compliant online is to put themselves in the consumers’ position – how easy is it navigate your website? Are the products and eligibility criteria listed clearly? Is information on financial planning signposted effectively to guide those less familiar with using a website, such as the elderly or vulnerable?
These are all questions that advisers should ask themselves when evaluating whether their website is up to the standard the FCA expects. Information needs to be presented clearly to customers, avoiding jargon and complex terms where appropriate. The website should also not push customers towards a particular product nor conclusion.
It also needs to be – for want of a better word – transparent. It should be as easy to make a complaint as it is to sign up to speak to someone about a new product or service. Gone are the days when someone would need to click through 100 pages before spying the information or details they need in small font in a sidebar.
So what next?
At Air, our ‘Insights Hub’ marketing toolkit allows members to utilize website tools that can be used to support changes made in accordance with Consumer Duty guidelines, ensuring customers are supported and guided effectively through the ever-evolving landscape of the market.
Given the importance of this legislation, there is also a great deal of support available for advisers on the wider topic of Consumer Duty from the industry. While our offering ranges from training on vulnerability to free access to the Comentis financial vulnerability assessment tool via our WriteRoute fact, lenders and networks have also produced different collateral that can be helpful.
We may have passed the initial deadline but Consumer Duty must be a top priority for firms, and regularly monitoring the compliance of your website will ensure that customers receive the best possible financial advice to help navigate their finances.
