Posted on Feb 28, 2023
We've been working with technology solutions provider Avoira on the introduction of a very smart, AI-powered interaction analytics tool, Xdroid.
The clock is ticking fast on the launch of the Financial Conduct Authority’s (FCA) new Consumer Duty regulations.
Financial services firms have until 31 July to subscribe to the new rules when applied to new and existing products or services which are open for sale or renew.
The new regime presents quite a challenge.
In an interview with Investment Week, the FCA’s executive director of consumers and competition, Sheldon Mills noted the “scale of reform” and the “substantial changes” it demands.
Further, the FCA’s guidance states that: “Our rules require firms to consider the needs, characteristics, and objectives of their customers — including those with characteristics of vulnerability — and how they behave, at every stage of the customer journey. As well as acting to deliver good customer outcomes, firms will need to understand and evidence whether those outcomes are being met.”
Talking to compliance professionals, at Avoira we’ve found that concerns lie not so much with adhering to the FCA’s outcomes-focused framework, but in providing the evidence that they’re doing so.
“Many Independent Financial Advisers (IFAs) and other financial services firms are understandably wary of the reforms because of their scale and reach,” says Kevan Thorn, Principal Consultant at IFA compliance specialist IFA Consultancy.
“However, in my experience, by and large they are already doing what they need in terms of achieving the kind of good customer outcomes the FCA seek.
“What does need attention is how they collate evidence to demonstrate good practice if required by the regulator. They need to show, for example, that they are able to identify and effectively support vulnerable customers.”
Sharron Titterington, Head of Compliance & HR (pictured left)at specialist broker Principal Insurance agrees. “The requirements and aims of Consumer Duty are not difficult for staff to understand, it’s the evidencing.”
She points out many brokers still rely on manual monitoring of randomly selected sample calls, which is both time-intensive and lacking in rigour.
That situation is further complicated by the requirement to ensure parity of outcomes across all channels. All communications should be “equally effective, regardless of the channel used”.
Whilst the FCA says it does not expect firms to capture every communication –calls, digital and face-to-face – it’s Consumer Policy Manager, Richard Wilson notes that this will be the best way to confirm they are understandable.
Principal Insurance is just one regulated firm to turn to Xdroid, a powerful omni-channel interaction analytics solution, to support implementation of Consumer Duty and the company’s wider business needs.
“Xdroid slots into Consumer Duty in so many ways,” says Sharron. “It can capture, transcribe, analyse and score every communication. It’s highly accurate, self-learning and our staff are very engaged with it.”
Her comments are echoed by Avoira CX Consultant Sam Goundry (right), who says:
“Xdroid’s technology allows for quick identification of potential vulnerability and a variety of high-risk call types, such as the provision of incorrect information or advice, and customer dissatisfaction.
“Using real time prompting, the technology can empower agents to influence conversations live in the moment, whilst notifying a manager when appropriate. This ensures customers receive the best possible experience and outcome.
“The detailed post call reporting also highlights any trends and allow the senior leadership team to make informed decisions on opportunities for further improvement.”
Xdroid offers many more general benefits which help underpin adherence to Consumer Duty.
For example, the metrics it yields can indicate when an agent or cohort requires new or refreshed training. “Through its agent and management dashboards, Xdroid offers continual assessment of compliance and wider performance,” says Sharron.
“Agents like that feedback and it incentivises them to improve, to beat their score.”
This chimes – in very much a belt and braces way - with the FCA’s guidance that firms should monitor their communications, identify and address issues and then retest.