Most readers of this journal will have some awareness of the FCA Consumer Duty. The important date when the new rules will apply is 31 July 2023 - not long now. In short it sets out to achieve an improvement in consumer protection by requiring financial service companies to deliver good outcomes for customers. Surely all financial service companies should be delivering good outcomes for customers anyway? That’s the expectation, but poor advice, poor governance around sales processes, and a culture that places more importance on sales rather than customer satisfaction led the FCA to conduct a detailed industry study in 2022. This led to the Consumer Duty implementation plans for 2023 and 2024. PwC has called the Consumer Duty a ‘paradigm shift’ in the expectation of the regulator in how financial service companies need to treat their customers. PwC identified five major challenges in the implementation of Consumer Duty: 1. Defining and monitoring good customer outcomes: Embedding the right governance to review data and identify concerns is essential. 2. Scrutiny over subjective judgements: Many FCA concepts are subjective - such as ‘fair value.’ Attention to interpretation of the rules is required. 3. Data: Poor data will make it difficult to justify outcomes. 4. Accountability: Staff training is needed, and customer interests need to become the heart of the general culture. 5. Supporting and empowering customers: Clear communication to help customers will be essential. Data and accountability are critical, because customers not only need to receive the best advice, but the brand also needs to be able to demonstrate that they always supported the customer in the most appropriate way possible. However, there is another factor at play here that may require a strategic shift for many financial service companies. The contact centre and customer service process has always been the interaction between brands and their customers. This is the frontline. It is where customers call for advice, where sales are made, and where customers with a question after a purchase can call and have their doubts calmed. Many financial service companies have seen their contact centre as a distinct process though, separate from teams such as marketing or sales. I think this is a mistake for a number of reasons. First, is that you can create a much smoother customer experience if the contact centre is coordinated across all these various functions. If your contact centre can advise, sell products, and help customers with a problem then that’s a lot more useful than telling them ‘we don’t do that here - call another number.’ It also opens your contact centre to the possibility of being a profit centre, rather than the traditional cost centre that most customer service teams are seen as. But importantly for the consumer duty regulations - the advice and recommendations your customers receive are now being scrutinised by the regulator. It’s not just the financial products now, it’s every interaction with your customers. Your customer service processes are therefore not just important for generating loyalty, they are essential for keeping your business on the right side of the industry regulator. Governance and compliance in customer facing processes is essential in this industry - especially from the end of July. The customer has to come first. Your entire customer-facing team must be oriented around the needs of the customer, rather than any internal targets they previously used to drive activity. Every financial service customer has to feel safe and well advised. This is going to need a full review of all customer-facing activities, not just sales. Compliance across all activities is actually a great opportunity to reframe how you interact with customers. Your contact centre has to be seen to be working towards a higher and clearer standard for customers. Are you already focused on making this happen?