Man and woman working on a whiteboard with post-it notes
Consumer Duty – time to set your plans in motion

Good for customers.
Good for brands.

The FCA’s Consumer Duty has now been published and marks one of the biggest shakeups in standards for financial organisations in a decade.

Its aim. To shift the culture of financial organisations to one that puts the customer firmly at the heart of everything – from product design and pricing to communication and support.

For financial services brands these new regulations are a chance to further strengthen their relationships with customers, build trust, increase loyalty and create future revenue opportunities – especially within customer communications.

At Signal we believe Consumer Duty will require organisations to fundamentally shift the strategy of how communications are planned, designed and measured to become truly customer focussed. The shift can be described as one:

From: Customer Communications Management (CCM) – where the focus is on the accuracy and efficiency of managing and delivering a communication output.

To: Customer Experience Management (CXM) – where the focus is on gaining customer insight and applying it to communications, so customers are equipped to make effective decisions and achieve their financial objectives.

‘A firm must act to deliver good outcomes for retail clients’

New Consumer Principle 12
A diagram showing the change in team structure over the course of the project

Four areas of expectation 

The good outcomes the FCA want to see fall into four areas:

  • Products and services
  • Price and value
  • Consumer understanding
  • Consumer support

And within these outcomes are detailed rules that will enable financial organisations to raise the bar and create the shift in customer experience the regulator is seeking.

See the full FCA Consumer
Duty consultation paper

Outcome 3: Consumer Understanding 

This is the FCA outcome focused on customer communications. It is here that we find rules and guidance to help create and deploy communications that support customers and enable them to make informed decisions about their financial products and services.

What the FCA want to see from organisations in this area:

  • Communications that equip customers to make effective decisions – by meeting their information needs, ensuring information is clear, fair and not misleading, and can be easily understood by the average customer. 
  • Tailored communications – to meet the characteristics of the retail customers receiving the communication – including any characteristics of vulnerability. 
  • Information provided on a timely basis – and that it is accurate and relevant to customers’ circumstance or point in their journey, and they can make an effective decision in good time.
  • Communication channel considerations – ensuring that, regardless of the channel, the information provided enables customers to assess whether the options available to them meet their needs and objectives and evaluate any relevant risks.
  • Testing and monitoring of communications – before communicating and regularly monitoring afterwards the impact of them. And using this insight to adapt communications where necessary.
A diagram showing the change in team structure over the course of the project

More together

At Signal we work with some of the UK’s biggest financial brands, delivering millions of customer communications every year. And since the FCA started work on Consumer Duty we’ve been helping them to understand the scope and scale of change they will need to undertake in response. Key areas of conversation have been around: 

Customer communication
Have we mapped these for all key products/moments?

Are the current communications enabling good outcomes for all customers including those with vulnerabilities?

Where are our gaps/areas where we need to improve?
Data and
How do we overcome the challenge of legacy systems?

Does our data allow for improved tailoring and personalisation?

Can our tech support additional/different channel choice by customers?
Testing and
How will we be able to evidence an increase in good outcomes?

What additional processes do we need to put in place?

How will we demonstrate where we’ve intervened and adapted communications?
As well as the huge implications on process, governance, and the control of communications across organisations.
Signal. No one else combines our strategic and creative expertise in the regulated space, with our specialist data and technology capability for the processing of non-marketing communications.

Start your own conversation about Consumer Duty with us today.
Call Ed Knight on 01242 258 731 or email