Consumer Duty FAQs

1.1 Is Consumer Duty the same as Treating Customers Fairly(TCF)?

No, the key difference between Consumer Duty and TCF is that Consumer Duty sets the expectation to provide fair outcomes for customers and the new expectation for firms to support providing good outcomes.

It’s a more proactive approach than TCF, which was reactive in its approach to providing good outcomes.

1.2 How will Management Information(MI) be shared ?

We’ll be communicating this in due course.We want to exchange data in a common industry format and for this we’re waiting on a template being defined by UK Finance.This will help facilitate consistent sharing of MI across the industry.

1.3 How will you treat a customer if an intermediary discloses they’re vulnerable?

We’ll always treat any customer who’s been identified as vulnerable individually, fairly and appropriately.We’ll communicate with them in a manner suitable to their circumstances and using any communication needs they may have, ultimately ensuring they’re generally supported in an appropriate manner.We’ve identified as part of our target market that a proportion of our customers may have vulnerable characteristics. Therefore, if we identify the vulnerability, or if you disclose a client’s vulnerability to us, we’ll record this and provide appropriate support. This may include contacting the customer, you or both to check if additional information is required to aid understanding or find out if we need to change how and when we communicate.

1.4 Will Consumer Duty lead to longer processing times for applications?

No, we don’t anticipate any changes to our application processing service levels because of Consumer Duty.

1.5 I’m being asked to accept terms and conditions, what do I need to do?

You‘d have read and accepted terms and conditions with us when you first registered on our portal.They haven’t changed following the introduction of Consumer Duty, but we have added some more information around the roles and responsibilities at the start of the document.

As it may have been a while since you first reviewed and accepted them, we wanted to give you an opportunity to review the additional information and read and accept them again.In order to submit business all you need to do is accept the terms and conditions again on the portal.