Kris Armstrong , Compliance Policy Manager , SimplyBiz

Before the recent deadline the FCA published 10 questions which they may ask firms in relation to their ongoing Consumer Duty compliance . These questions are relevant to protection advisers , so here ’ s some practical guidance and support .

1 Are you satisfied your products and services are well designed to meet the needs of consumers in the target market , and perform as expected ? What testing has been conducted ? It ’ s important to have established clearly defined target markets for your services , including consideration of specific client segments or any negative target markets . For example when a client approaches you during a significant change of circumstances , or clients just want to insure against the unforeseen . Your service should be inclusive and designed for those consumers that don ’ t fall within the limitations of your service .

2 Do your services have features that could risk harm for groups of customers with characteristics of vulnerability ? If so , what changes to the design of your products and services are you making ?

If a consumer with a perceived vulnerability falls within your service , adaptations may need to be made according to the needs of the consumer . Firstly , you should undertake an assessment of each client to determine whether a possible vulnerability is present . Situations where a vulnerability may compromise the value of your service as a firm may be language barriers or particularly those who because of circumstance lack the adequate budget for the protection needs . An adaptation could be made by giving additional time and support to ensure the client understands the information being presented and it ’ s implications to reduce the risk of harm whilst ensuring key protection needs are still met . Visit the Vulnerability Hub on our website to access our vulnerability assessment tool and other supporting templates and documentation .

3 What action have you taken as a result of your fair value assessments , and how are you ensuring this action is effective in improving consumer outcomes ? For protection firms fair value assessments are a great opportunity to discover how they truly achieve good consumer outcomes . In addition to carrying out the necessary due diligence on your products and services , the fair value assessment is a great chance to assess all the benefits you offer , from the knowledge and expertise of your underwriting criteria to the support offered at times of crisis , which is of particular value at the moment during a cost of living crisis when extra assistance may be required for those clients who feel they can ’ t afford their policies . Fair value assessment templates are available within the SimplyBiz Consumer Duty Hub .

| PROTECTION ADVISER | AUTUMN 2023 | 13