4 What data , management information ( MI ) and other intelligence are you using to monitor the fair value of your service on an ongoing basis ? The expected level of MI will be linked to the size and capacity of your firm and above all the risk that customers may pay for your services and not realise value , so for a protection firm that offers fee free advice then the issue of value may be simpler to prove . Consumer feedback is the easiest way for firms to evidence value . Who better to evaluate your value than those whose financial objectives you are delivering ? Firms should be inviting feedback , the recent financial lives survey indicates trust and satisfaction is high amongst those who access advice , so surveys , net promoter scores and mystery shopping or other customer research are a great way to vindicate the service you offer as a firm . Even where complaints arise , by performing root cause analysis you can establish whether the service you offer needs adjustment . A client feedback tool template is available within the SimplyBiz Consumer Duty Hub .
5 How are you testing the effectiveness of your communications ? How are you acting on these results ? Nobody knows your clients better than you do , however , it is important communications with your clients should be able to be understood by those receiving them . Where the firm identifies a customer needing additional support , adaptations to communication channels should be made according to client needs , whilst communications should be issued in good time and using appropriate channels for different groups of clients . The best way to monitor the effectiveness of your communications is positive friction throughout the advice / sales process , for example inviting customers to replay key information in their own words and keeping records on file accordingly .
6 How do you adapt your communications to meet the needs of customers with characteristics of vulnerability , and how do you know these adaptions are effective ? Consumers with a vulnerability may not be immediately obvious . We have vulnerability assessment tool from Comentis to aid you with this . Advisers should talk through the key features of the document , allowing those with a low level of financial sophistication to ask questions and advisers to take steps to confirm the client understanding . SimplyBiz have recently published on the operating centre guidance on ‘ Read aloud ’ functionality for electronic documents and there are many other adjustments that can be made to support the needs of a vulnerable customers ( e . g . offering family / friend meetings or facilitating contact through communication channels that suit the client ). Any steps taken should mitigate harm and empower the customer to engage in the advice process , rather than your firm simply recording the vulnerability on file .
7 What assessment have you made about whether your customer support is meeting the needs of customers with characteristics of vulnerability ? What data , MI and customer feedback is being used to support this assessment ? The firm should have an up-to-date and personalised vulnerable person ’ s policy which is kept under review . The VP Policy sets out how to maintain records and keep outcomes under review . However , meeting the needs of potentially vulnerable customers goes beyond an up-to-date Vulnerable Persons Policy . The adaptations that the firm makes to its advice process to support the needs of a vulnerable customers should be recorded with these steps maintained on file for future reference . Again , client feedback is important . Internally , there should be ongoing discussion around the issue of vulnerability , possibly making use of third-party support to educate staff . With the current cost of living crisis and the FCA ’ s guidance on supporting customers in financial difficulty , signposting and the firm ’ s non-earnings register are important when assisting clients with this vulnerability of low financial resilience . As a protection firm you should be monitoring persistency and those recommendations that are made where there is a client need but the recommendation is not taken up .
14 | PROTECTION ADVISER | AUTUMN 2023 |