FCA Consumer Duty Mandates are Coming. Is Your Contact Centre’s WFO Solution Up to the Task?

July 2023: FCA consumer Duty will put your contact centre’s compliance and quality management capabilities squarely in the spotlight.

As retail financial service organizations are discovering yet again, navigating the regulatory environment never gets easier; any movement leads in the direction of new and more stringent mandates. By July 2023, industry players will be required to comply with the Financial Conduct Authority’s (FCA) Consumer Duty of Care (CDC) rules, compelling financial service providers to “act to deliver good outcomes for retail customers” relating to:

  • products and services
  • price and value
  • consumer understanding
  • consumer support


Points of emphasis that should be included in any FCA Consumer Duty summary are:

  • end unfair charges and fees
  • make it as easy to switch or cancel products as it was to take them out in the first place
  • provide helpful and accessible customer support, not making people wait so long for an answer that they give up
  • provide timely and clear information that people can understand about products and services so consumers can make good financial decisions, rather than burying key information in lengthy terms and conditions that few have the time to read
  • provide products and services that are right for their customers
  • focus on the real and diverse needs of their customers, including those in vulnerable circumstances, at every stage and in each interaction

Vulnerable Customers

Per the FCA’s website, the rules require contact centres to step directly into their customers’ shoes and consider their needs, characteristics and objectives. This includes customers that fall into the FCA’s definition of “vulnerable”. Every step of the customer journey must be examined, and the company must act to deliver good customer outcomes at each step. Moreover, they may be required to prove they’re achieving those outcomes for customers.


"Vulnerable" customers include the following:

  • People will health issues that prevent them from working
  • Unemployed people
  • People needing to be looked after by caregivers
  • People who are caregivers and therefore cannot work or work full time
  • People with addictions including alcohol and gambling
  • People who going through a relationship breakdown such as a divorce
  • People who are vulnerable because of a major change in life circumstances - moving house
  • People experiencing bereavement
  • Armed forces personnel who have recently returned to civilian life


Estimates are that approximately 50 percent of the adult population falls into one or more of these categories. That’s an important statistic for companies regulated by the FCA Consumer Duty mandates since they'll need to show that they’re monitoring a large enough sample of their transactions to ensure they are picking up on vulnerable customers. Moreover, they’ll need to prove their treatment of vulnerable customers is in line with the rules specified in the CDC.

Your Contact Centre Is In the Spotlight

The implications of the new CDC directives touch on everything from company culture to the customer journey. However, looking at it more narrowly, from a day-to-day operational perspective (where the rubber meets the road), all roads emanating from CDC lead directly to your contact centre and its compliance and quality management tools and processes.

Everything’s in play, from improving your contact centre’s service levels and reporting capabilities to advancing your agents’ skills and your analytics competencies. In short, you need to harden your contact centre operation or risk falling short of the CDC mandates. Your contact centre workforce optimization (WFO) software will play an outsized role in determining success or failure.

Contact Centre WFO Software: Must-Have CDC Compliance Features

Contact centre’s in the retail finance industry can only ensure compliance with the consumer duty mandates if their leadership can exercise control over the thousands or tens of thousands of inbound or outgoing interactions their organization handles daily. Certain capabilities within a WFO solution are absolute necessities when it comes to maximizing that control:

  • Omni-Channel Capture – Recording for voice, chat, email, text, screens and video. Single repository for support, sales and back-office transaction recordings, and automated recording categorization by type, source and customer.
  • Auto Pause & Resume – APIs, toolbars and automated rules for pausing recordings to protect customers’ personal financial information.
  • Live Monitoring – Provides the ability for contact centre supervisors to listen to agent/customer phone conversations and view screens in real-time, simultaneously coaching as necessary.
  • Media Lifecycle Management –Archive datasets based on configurable rules and automatic categorization.
  • Audit Protection – Detailed audit logging for every system action. Simplified extracts during compliance reviews.


Beyond just capturing and storing every interaction lies the ability to analyze each of them – or at least a large percentage - because large-sample analytics yields accurate decision-making insights that can directly impact an organization’s ability to comply with FCA Consumer Duty rules.

For instance, in the case of voice interactions, a financial services organization might be well-served to know if agents in their call centre are using keywords or phrases in their conversations with vulnerable customers that might raise a red flag with auditors. Or it could be helpful to analyze speech patterns, voice inflection and even periods of silence during a voice interaction to identify moments of customer frustration or agent unpreparedness. Essentially, contact centre managers in the financial products/services industry can use any number of interaction recording and speech analytics tools to gain insight into the organization’s CDC compliance efforts, insights they can use to:

  • Equip agents to efficiently and correctly resolve every customer encounter per FCA-CDC requirements
  • Identify agent knowledge gaps and training needs.
  • Identify emerging issues that could impact FCA-CDC compliance
  • Integrate the FCA-CDC framework into contact centre processes
  • Identify sources of customer dissatisfaction
  • Identify quality management process inefficiencies

The FCA Consumer Duty mandates are just the next step in the industry’s evolution, which is always (and appropriately so) pushing to raise the standards for customer service, satisfaction and protection. Look at it as a mandate for improvement. Achieving that mandate won’t be easy, but it will be easier - and most importantly, it will be assured – if you have the right contact centre compliance and quality tools and technologies to support you.

 

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