James Hay’s former customer experience head has launched a service which helps companies gather feedback from employees and clients to understand whether or not they live up to the incoming consumer duty.
James Edmonds has developed two surveys which separately target employees and clients.
They plug into a ‘feedback hub’, which gives firms a breakdown on where they meet - or fall down on - the Financial Conduct Authority’s criteria.
The idea is to give employees an opportunity to anonymously call out internal practices, such as companies charging inflated insurance premiums, or making exits from a service expensive and cumbersome.
Then in tandem, the other survey will gather data from customers on their interactions with the company.
Currently, Edmonds is overseeing a pilot with a small handful of clients.
The FCA’s consumer duty deadlines require firms to have implementation plans in place by next month, with plans to be implemented for new and existing products by July 2023, and for back books by July 2024.
The duty requires firms to prove to the regulator that they are actively avoiding consumer harm and assessing the effectiveness of their actions.
“Our view is to focus on advisers. Larger firms have cross-functional teams. It’s the smaller firms with less resources which will need to outsource at a relatively low cost,” Edmonds told FTAdviser.
“Organisations don’t realise how big this is. The guidance is deliberately vague so it can be far-reaching.”
The feedback hub singles out different consumer duty metrics, and then explains where exactly a firm may have gone wrong.
For example, if a company is not ‘avoiding unforeseeable harm’, it can drill down into why this.
For example: Is the number of complaints letting it down? Are there holes in governance? Is information being managed effectively? Are the risk frameworks stringent enough? Or is the firm’s back book posing the biggest challenge?
On a consumer side, the survey data helps firms deduce anything from whether consumers can easily exit their service, to how their care of a customer performs over the lifetime of a product.
The startup charges £4,500 for internal gap analysis, and £7,950 for both the internal and customer-facing surveys.
‘I’ve been a vulnerable customer myself’
Edmonds has spent time at previous employers like James Hay, and particularly Just Group, working on how to best serve vulnerable customers.
But it was a personal experience which really highlighted to Edmonds the importance of financial services companies being able to identify customers going through hardship.
“I’ve been a vulnerable customer myself. I wasn’t treated well at that point in my life,” he explained.
Edmonds was due to get married. He and his fiancé had wedding insurance. In the lead up to the event, Edmonds’ sister collapsed while on a family holiday in South Africa and suffered a number of seizures.
