Consumer Duty requirements – the customer journey lens

Have you thought about mapping Consumer Duty requirements against end-to-end customer journeys?

Many firms initially chose to focus on Consumer Duty requirements and defining good outcomes through a product rather than a customer journey lens.

At a surface level there may seem nothing wrong with this. However, as part of fully embedding Consumer Duty it’s important to also think about how the different services and information the customer receives during a journey interact together to deliver outcomes.

For example, reviewing communications in isolation to ensure they read well and provide a good level of understanding is clearly essential. But taking that extra step, and thinking about how and when those communications are received and how they might interact together to ensure they deliver a coherent, easy to understand message, is crucial to successfully embedding Consumer Duty in the long term.

Mapping key customer journeys and logging Consumer Duty requirements against them also has significant benefits. For example:

1. It enables firms to connect their operational risk framework with Consumer Duty embedding, by mapping risks and controls to stages of the customer journey, helping them identify gaps where risks aren’t sufficiently mitigated. This improved matrix approach to monitoring and managing risk within the business can ensure risk management lives and breathes as part of the day-to-day management of products and key processes.
2. It allows a firm to demonstrate to the regulator it has defined what good outcomes look like during journeys, identified how it will deliver good outcomes and monitor them across end-to-end journeys. This will support identifying the right management information (MI) required to monitor as well as drawing out risks and controls. Good quality MI, which contains a mixture of lagging and leading indicators, is key to ensuring there is proper and appropriate oversight.
3. It can also help enhance the quality of journey outcome testing, by identifying risks and points for review. It is important that firms are conducting a range of different types of outcomes testing, that is informed by the stages and risks in the customer journey, and enables firms to demonstrate they have a holistic testing process that will identify issues that may not have been easy to spot simply by reviewing MI.
4. It also provides firms with the opportunity to identify improvements to the customer journey, such as simplifying steps, delivering information in a more logical manner or improving customer understanding. Some of these improvements can drive operational efficiencies and savings as well as delivering good customer outcomes.