This might also include reviewing customer files and monitoring calls to check for errors and assess if customers received good outcomes, as well as checking compliance reports.
Sharing information
Not all the information you collect will come from your own sources – and be aware you may have to share your information with others, if asked.
The guidance suggests that firms "may want to include" feedback from other parties in the distribution chain.
There’s actually an existing rule which still applies that "to support manufacturers, distributors must, upon request, provide relevant information, including, where appropriate, sales information, information on cancellations, and information on the regular reviews of their distribution arrangements".
Therefore, be prepared for incoming requests from other firms looking for evidence that they’re complying with the new rules.
Customer behaviour and feedback
Research that shows you’ve looked at customer behaviour such as interactions and drop off rates, your use of different communication channels and consumer testing of user interfaces such as websites and apps will be relevant.
Is anything getting in the way of consumer engagement or understanding, for all or some of your target market?
As well as the traditional customer feedback route, the FCA suggests you can use comments and complaints on social media to identify trends and areas for improvement – although equally you can use happy customers to show evidence of where you’re achieving good outcomes.
External research
You can also use external research to show how your products and services fit with the outcomes you’re aiming to achieve.
The FCA helpfully suggests its own Financial Lives consumer segmentation survey of 250,000 households – data due soon for 2022.
If you want, and have the budget for, research more specific to your firm, you could use external consultants, mystery shopping, focus groups, or work with consumer organisations to provide the evidence that you understand your target market.
Staff
Your own staff can provide evidence of how well you’re achieving your objectives.
Staff training, including remedial actions and having processes in place to allow staff to feed back honestly on products and services, can all be taken into account.
If that looks like a long list of suggested data sources, bear in mind that while the ultimate objective of all this is to have sufficient information to be able to identify whether you’re delivering good outcomes, there’s an inbuilt flexibility in how you go about it.
If you want an even more detailed list you can head over to paragraph 11.33 of the finalised guidance.
Alison Gay is senior public affairs consultant at the Lang Cat and a former senior associate at the FCA
