QUICK GUIDE TO
CONSUMER DUTY OUTCOMES 3

The FCA want firms to make sure that clients understand what they are being told and sold. The idea
is that if they understand fully, they can make properly informed decisions and are more likely to
achieve their financial goals.

You need to make every effort to ensure that your communications are clear, relevant and transparent about risks and rewards. These efforts can be usefully broken down into two stages: how your communications are created, and how they are monitored and tested. The latter stage will be important to demonstrate how you have worked to achieve this outcome.

• All communications should follow established clarity guidelines, such as using plain English, using subheads and visuals to guide the reader’s eye, layering with digital links, and ensuring consistent terminology across touchpoints.
• Particular care should be shown with communications that directly impact clients’ decisionmaking, such as suitability reports and annual reviews. But the Duty’s requirement applies to all communications including advertising and PR messages, and materials from providers.
• All communications should be written with the reader front of mind, with awareness of any personal vulnerabilities and of critical timings in their product lifecycle, such as contract breakpoints.
• Proper weighting should be given to risks and costs as well as potential rewards. This includes charges and fees: the FCA has found that poor disclosure of these has been a consistent problem.

The FCA wants evidence of firms checking the comprehensibility of their communications. This means testing communications before release, and monitoring their performance after release, so they can be improved if necessary.

• Not everything needs to be tested but new communications and any that have generated poor feedback in the past should be.
• If you don’t have something like a Client Communications champion, it’s a good idea to appoint or assign one to help manage testing and monitoring.
• There are many ways to test, from simple 1-1 questioning to full focus groups and surveys, but the FCA wants to see evidence of appropriate testing and improvements being made.
• There are also several ways to monitor, such as examining test data, checking where clients followed calls-to-action or dropped-out of digital flows, working on complaints and showing how your company responded to them.