Greetings – Mike here again. Apparently, my Update from a couple of weeks ago was so popular that our dear readers have been LITERALLY BEGGING for me to come back. Either that or Mark is still on holiday…
Anyway. Lots on my mind this week. Our recent advice gap paper launch is still getting loads of nice coverage (see links below) with lots of nice people saying nice things about it all. Which is nice. No rest for this feline though as a couple of large projects are kicking off. More to come in the Autumn for both of these.
In the meantime, I’m sure everyone is as excited as I am about the imminent first birthday of Consumer Duty. They grow so quickly etc. To mark this event the FCA are holding a webinar on 31st July that you can register for here. It’s encouraging to see this will not only include some backslapping, but also examples of good practices and areas for improvement.
In addition to this webinar, the anniversary is being commemorated by approximately 450 million articles about how it has all gone. “Consumer Duty is great news for Guatemalan leveraged investments, says leading provider of Guatemalan leveraged investments.” The ones based on adviser research are, however, more interesting. This one being a good case in point.
Our own research supports this positive sentiment from the advice sector. Yes, Consumer Duty needed some work to implement, but the objectives are sound and the process of implementing the changes has invigorated many firms. A clearer target market, a collective focus on ensuring fair value and delivering good outcomes? What’s not to love?
Halfway through the Update, so time to pivot towards the point. Whilst the positive sentiment towards Consumer Duty is there, and we can evidence it has been the catalyst for positive change, it is also serving to shine a light on areas that desperately need improving.
The mighty Jack Gilbert & Victoria Bell published a piece on platform transfers this week, showing where improvements are still needed. “Platform transfers are only ever as strong as the weakest link in the chain,” said some bloke called Mike Barrett back in 2013. 11 years, one Platform Market Study and 12 months of Consumer Duty later it is astonishing to see this is still an issue.
However, many advisers tell us that it’s not just platforms. Pension trustees and scheme administrators are where the fun really starts. These firms are not impacted by Consumer Duty, yet the people they are attempting to serve are. I’ve seen several examples of advisers identifying clear customer detriment and Foreseeable Harms in the direction of these providers, with their pleas for just a bare minimum of service and contact falling on deaf ears. Again, this needs to improve.
The final area where I see need for real improvement is in how some firms handle customers in vulnerable circumstances. Those of you who know me will know this is has been something that I’ve had to deal with recently. Some firms have been excellent. Others made a difficult time even worse.
With the first birthday webinar just around the corner it is clear that the FCA will be continuing to ensure that Consumer Duty is properly implemented. They have already flagged additional work in the vulnerable customers space, and I’d urge them to follow this up by finally addressing the issue of transfers. Our advice gap research showed early signs of improvements in consumer perception of financial services since Consumer Duty was implemented, but a lack of trust still represents a significant barrier to paying for advice. More importantly, behind every single one of these examples of poor service, delayed transfers and the like sits an individual consumer. The very person Consumer Duty was designed to protect. Year one was about embedding the rules. Year two should be about enforcement.
And to close – loads of good new music out at the moment. The Michael Kiwanuka record is beautiful, there is a new Kim Deal song that really should get the link, but that prize goes to the incredible Ezra Collective. Jazz on TCWU? This is what happens when the boss is away….
