FURTHER SUPPORT
8 How have you satisfied yourself that the quality and availability of any post-sale support you have is as good as your pre-sale support ?
Arguably file reviews are the best way to ensure that advisers are following the advice process and that client files are of an acceptable standard . Each firm should have a file review process where file checks are carried out in line with the firm ’ s Training and Competence Plan . Where a file review results in an unclear or unsuitable outcome , the firm should take steps to address this both with the affected client and with the adviser . This is then recorded and considered in respect of the advisers T & C Plan . File review support is available from our Advice Quality Team , for further details please contact aqt @ compliancefirst . co . uk .
9 Do individuals throughout your firm – including those in control and support functions – understand their role and responsibility in delivering the duty ? The 3 Cross Cutting rules and 4 Consumer Duty outcomes should be actively engaged upon and at the centre of the firm ’ s ethos with the Consumer Duty fully implemented with a top-down approach from management . The firm could regularly hold staff meetings to discuss the Consumer Duty and its impact and expectations with annual reviews of Fair Value reported to management , whilst larger firms should encourage and support the role of a Consumer Duty Champion within the business . This extends to altering service for your firm , for example where the firm is sacrificing commission for a client , senior management sign off should be in place .
10 Have you identified the key risks to your ability to deliver good outcomes to customers and put appropriate mitigants in place ? There are many risks within a protection firm to not delivering good client outcomes and it is management responsibility to ensure monitoring is undertaken on an initial and continuing basis . For example , protection provider criteria should be continually reviewed by advisers , and there should be controls in place to ensure there is no commission bias . Due diligence will extend to many aspects , from research tools to your knowledge of an Insurers ’ ABI + definitions . This should be carried out on an initial and continuing basis with results reviewed and recorded . This involves periodically reviewing products sold that may no longer represent good value , for example where insurance or protection terms become more competitive as products evolve with enhanced or additional conditions covered by providers or add-ons that are provided inclusive of the insurance product .
FURTHER SUPPORT
VISIT THE CONSUMER DUTY HUB
Log in to the website and go to the Consume Duty Hub for further support in managing your Consumer Duty responsibilities . Details of the client feedback and vulnerability assessment tools referenced in this article can also be found there .
COMPLIANCE SERVICES
Log in to our website and navigate to Compliance to access help with any regulatory issue , from assistance with file reviews and advice quality to team training , TC & C and more .
Or just contact us at 01484 443 445 or compliance @ simplybiz . co . uk
| PROTECTION ADVISER | AUTUMN 2023 | 15