Consumer Duty Portals: How providers and platforms can meet Consumer Duty obligations through modern portals

09 May 2023

By 31 July 2023, providers and platforms will need to have systems and processes in place for gathering and analysing a great deal more data about their policyholders with a view to discharging their new Consumer Duty-linked responsibilities efficiently, effectively and in a way that can be audited by the regulator if necessary.

In essence, providers, platforms and advisory firms will have to do the following with a view to achieving better outcomes for customers:

• Provide clear and timely information about the products and savings they have so they can make informed decisions without delay.
• Check and note the engagement levels of their customers by keeping track of what they have read and understood.
• Ensure products are still meeting customer needs as their circumstances (potentially) change.
• Recommend alternatives where legacy products are out of line with known customer needs.
• Improve customer service elements - ensuring that customers can communicate with their financial product providers through preferred channels when they really need to.
• Ensure the customer is getting fair value for the products and service for which they are paying.

Consumer Duty presents a threat to providers and platforms if they do not serve their customers in a more direct, interactive, meaningful and effective way. They must work harder to really ‘Know Their Customers' and act on any new knowledge to steer policyholders away from poor financial outcomes. However, Consumer Duty also presents a massive opportunity for providers and platforms to serve their customers in a more personalised and engaging manner via the array of interlocking digital channels now available to them.

As we see it, portals and companion mobile apps which offer accessible views into those portals from customers' smartphones, are a clear route forward for market participants looking to ensure better customer outcomes, in line with Consumer Duty obligations.

Those of us lucky enough to benefit from regulated financial advice - that's somewhere between 5.7% according to the regulator, and 8% of the UK population according to Platforum's latest analysis - may well be connected with an adviser portal whose dashboard could look a little like the above.

It's conceivable now that many more providers will need to create customer, as well as adviser, portals to hold statutory documentation, valuations, up-to-data customer data, secure messaging capabilities and more. These portals must stimulate customer self-service and self-updating of personal details wherever possible. But they must also stimulate further enquiry if it looks like any new customer data coming in might demand policy or portfolio changes.

Pre-Consumer Duty, most providers focused policyholder communications on posting out paper-based statutory documentation such as pensions annual benefit statements and valuation requests. Communication was one way, rarely read and even more rarely acted on, unless an adviser was supporting that customer. No checks were run to make sure policyholders had read and understood these documents.

In the digital portal-led world all that changes. It becomes relatively easy to ‘upgrade' customer communications to make it much more interactive, personalised and, dare we say it, interesting! You can encourage customers to update their personal details as their circumstances change. Changes can be logged there. You can make it worthwhile for them to update you, by providing automated recommendations or alerts if new information suggests that now is the time to consider increasing those pension contributions, beginning a de-risking glidepath ahead of earlier retirement target date, and so on.

And where does this leave the 8% of us using a regulated financial adviser regularly? One option for providers is to make sure alerts about communications, which are about to go to their customers, are pre-sent to their advisers via a dedicated adviser portal.

In this way, any client data updates which have flowed to the provider or platform can be shared in a timely way with the relevant adviser first - giving them time to prepare and share a range of options, based on this new information or change of circumstances, with their customer.

Providers may also choose to share engagement level indicators with advisers - again gleaned from their customer portal. So, if a policyholder is clearly not reading any of the documentation being sent to them, or logging onto the portal to view updates, advisers connected to those customers could be alerted that, for whatever reason, the customer has disengaged. It could be a trigger for that adviser to pick up the phone to book in a financial health check, for example.

Secure Portals

Dunstan Thomas has been building both provider and intermediary-led portals for more than ten years now. We have worked with a number of firms to bring disparate online service offerings together into single modern flexible and yet highly secure portals, often supported by two-way authentication. Where online access has been previously cumbersome, we support clients to modernise their online interface's look and feel to improve user experience.

The result is that clients that were previously slow to adopt new online services become advocates. Contact centre workloads then fall as more customers self-serve - enjoying slicker digital customer experiences which ensure they can gain access to the information they need faster. So, building these slick and highly engaging online environments tailored for both advisers and end customers to support Duty obligation is now much quicker, easier and less costly.

The Financial Conduct Authority's new Consumer Duty creates an opportunity for firms to lead on data-driven innovation. The regulator will shortly begin examining how firms are delivering good consumer outcomes. It will assess if firms are putting all available data to work to deliver the right outcomes for customers, regardless of whether they are providers or advisers.

Firms will increasingly use data to gain insight into changing customer needs. This data must also be used to help direct product innovation. High-quality, up-to-the-minute customer data will quickly prove to be essential in delivering better outcomes and achieving compliance with Consumer Duty regulations.

So, creating highly engaging portal environments which serve to stimulate two-way, increasingly interactive data flows between the client and product and platform providers, can only support better customer outcomes over time.

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