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How to Prepare Your Customer Communications for the New FCA Consumer Duty Rules

How the Consumer Duty regulations are set to change financial communications in the UK

In July 2022, the FCA published their final guidance and rules on the new Consumer Duty standards. It resulted in sweeping changes to financial communications. Here’s a summary of what these changes are, and an action plan to ensure your content is fully compliant.

What are the new FCA communication rules?

The FCA Consumer Duty is aimed at ensuring consumers receive:

  • Communications they can understand
  • Products and services that meet their needs and offer fair value
  • The customer support they need, when they need it.

Why do the new rules exist?

The new FCA communication regulations are set to help customers make more informed financial decisions during a critical period as the cost of living rises.

The emphasis is on giving consumers the right information, at the right time.

The new requirements seek to:

  • Make it easier for customers to cancel or switch a financial product
  • Give consumers more accessible customer support and advice
  • Add clarity and accessibility to key information around products and services
  • Ensure consumers are provided with products that meet their needs
  • Ensure diverse needs are addressed in every interaction, and at every stage of the customer lifecycle

The FCA Consumer Duty comes at an opportune moment; Buy Now Pay Later schemes and high-risk investments like cryptocurrency and NFTs are flooding the market. The regulations also seek to address problems surrounding the time taken to consider a purchase when consumers have been reached through social media and other online advertising.

This comes during a cost of living crisis when many will receive increased communications from financial services companies.

When do the FCA Consumer Duty rules come into force?

27th July 2022 – Final rules and guidance published
31st July 2023 – Rules start for open products and services
31st July 2024 – Rules start for closed products and services


Understand the rules

Even organisations that provide products and services but do not have a direct relationship with consumers will be bound by the new Consumer Duty.

The best way to understand the rules is to read the FCA’s Final Non-Handbook Guidance. We’ve also summarised it and added some tips below.

The two main questions to bear in mind are:

  • Are your communications clear to your audience, taking into account their financial literacy?
  • Is the quality of your post-sales messaging the same as your pre-sales communications?

Check your customer journey

The FCA’s guidance focuses on the full customer journey. You need to have a list of all of your customer touchpoints, where they are in the journey, and which customers are likely to receive communications from you at each of these touchpoints.

Go through the pre-purchase, purchase, post-sales, and post-customer journey yourself, and make a note of each time you receive a communication. Examples and templates for customer journey mapping.

Create a timeline

It’s important that due care and attention go into amending your products and services, and the wording around them. If you don’t have the internal resources needed to make the necessary changes, consider hiring a copywriting agency.

How to ensure your financial communications are clear and in line with the FCA Consumer Duty Rules?

Test before you create your wording

If you have time, it’s important to test your messaging on similar demographics to your target audience and customers before it goes out to real customers. Use focus groups, surveys, outside agencies, and other methods to perfect the wording.

Continually test your messaging on real consumers

Test your messaging through customer surveys, while ensuring your feedback collection methods are robust (from call centres, for example). You should also examine data like open rates, click through rates, and action taken. It’s important to set up benchmarks and KPIs for each metric to ensure you’re communicating with customers in the best way possible.

Data to use to test financial communications:

  • Customer response rates, where action is required
  • Analysis of whether customers are following instructions, and the process they go through when they do
  • Open rates
  • Click through rates
  • Responses and drop-out rates at each stage of the customer journey
  • Product take-up rates
  • Product switching rates
  • Claim rates
  • Complaints data

Use a copywriting or communications team, alongside your compliance team (well, we would say that)

Copywriters and communications specialists are experts at speaking your customers’ language. If your team is particularly effective at marketing copy, use their expertise across all of your correspondence.

Handle toss-ups between compliance and communications teams

With these new rules in place, you’ll need to use words that ensure your business remains compliant while also making sure customers can understand the message clearly. This could mean using industry terms in an adjoining document, while attaching a letter which breaks down their meaning.

Remove industry jargon wherever possible

Testing writing on customers, using professional copywriters, and developing close working relationships between marketing and compliance will help you remove industry terms that consumers struggle to understand.

Keep a conversational, but serious, tone

Conversational writing is easier to understand. Even if your target audience is fully fluent in financial-ise, they’re not being paid to read your content. Make sure you keep it easy to read.

Use bullet points, short sentences and paragraphs, and clear headings where you’re able to

Any of the tips you’d apply to marketing copy also need to be applied across all your communications.

Create different communications for different groups of customers

The FCA is very clear that customer segmentation is key. Split customers into groups with similar levels of financial knowledge who are likely in need of similar advice. Then, write separately for each group.

Help customers to navigate the information you provide them

For example, with a central location with links to each document and a short description of what each document is.

Create a clear user journey

So customers can understand their options, and where they are in their journey. It’s helpful for internal teams to create a visual map of the customer journey.

Ensure communications are given in a timely manner

Give your customers plenty of time to make the right decisions based on the correct information.

Pay attention to the channel you use

Different channels will need different amounts of wording vs. visuals. For useful documents, customers may want a physical copy, along with a digital copy, and some channels like mobile may not support all of the information you need to display. The FCA suggests not allowing customers to read large amounts of information on mobile, but instead moving them to paper or desktop communications.

Make the most of channels where you communicate with customers 1 to 1

For example, phone support. This is a perfect opportunity to ensure your customers understand the information and have everything they need to make an informed decision.

Consider using infographics and clever design

These are effective ways of ensuring customers understand the most important messages, particularly when it comes to consumers with conditions like dyslexia.

Pay attention to content surrounding how customers can switch and complain

Use as many resources for this as you would for content about how customers can buy your products or services.

Layer your communication

This could include adding links so customers can find out more information when necessary.

Ensure your content is as engaging as possible

It’s essential that each sentence is easy to read and leads on to the next one.

Make the Call to Action as clear as possible

Make sure you clearly explain what your customers need to do, along with when and how they can do it.

Use question and answer formats

They’re quicker to read and provide customers with the information they were looking for.

Use icons, tables and bullet points

Wherever you can. They help split the information out well.

Avoid extraneous information

It can be tempting to tell customers about similar, useful products. But, you should ensure your communication remains clear and only includes the most useful information.

Include absolute costs

Rather than percentages, interest, or daily costs (for example, an overdraft looks a lot more affordable at a daily cost rather than an annual one).

Give examples where possible

Borrowing £100 over 1 year will cost you £5 in interest, paid at £1.75 per month from 31st July 2024. Splitting this out into a table is helpful.

Check the frequency of your communications

Ensure you aren’t sending out information so often that customers miss the important bits. On the other hand, make sure you aren’t sending it so infrequently that if they miss one email they won’t be able to make informed decisions in a timely manner. Check email open rates, click through rates and actions taken, and make sure you’re always testing.

Check your communications on all devices

And, check you’ve given customers the communications on the appropriate channel. For example, some visually impaired consumers may ask for emails rather than large text letters.

Include inclusive design

Make sure customers with disabilities are equally able to understand the communications.

Have a range of communication options available

Including braille, large font, and visually designed. You should also have the same messages ready to send via email, text, and post.

How the new rules work with existing communication compliance for financial services

Product-specific rules will take precedence. But we recommend creating compliant communications and then adding cover letters with a clear breakdown of the most important information, where possible.

Looking for help creating clear customer communications? Try our clever copywriting service, or get in touch.

New FCA Consumer Duty Rules - customer journey map

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