Assurant Consumer Duty plan - Update to distributors

Why you should read this

Consumer Duty is the FCA’s flagship program which sets higher and clearer standards of consumer protection across financial services that requires firms to put their customers’ needs first. As a distributor of our products you have a duty to comply with the regulation.

Our approach to Consumer Duty

Implementing the FCA’s consumer duty requirements is an essential step in providing high quality services to our customers, building strong reputations, and achieving long-term success. We want to ensure we prioritise the interests of our customers, treat them fairly, and provide them with clear and accessible information.

Our dedicated project team is leading our implementation with subject matter experts from all departments, with a clear focus on achieving the 31 July 2023 deadline, and communicating any changes to our distributors by 31 April 2023. 

What we’ve done to date

• Developed an implementation plan, which was approved by our Board in October 2022
• Formulated a detailed framework to describe how Consumer Duty will affect each business function, and what needs to be conducted to comply
• Identified all focus areas and products required to successfully comply with Consumer Duty by 31 July 2023
• Confirmed products which are defined as being closed and will comply by 31 July 2024
• Working parties have reviewed all customer touchpoints to ensure all actions are identified
• Defined how we are going to monitor and evaluate adherence to Consumer Duty through each customer touchpoint
• Founder member of the Harris Research insurer consortium to provide us with the ability to measure customer understanding of any communications

 

We have focused our activities into the following 4 stages:

 

 

Where the analysis has been conducted and split into these categories:

 

Our existing governance processes already placed us in a strong position to meet Consumer Duty requirements, and through our monthly Customer Experience Forum we are continually monitoring and looking for areas where we can enhance or improve the customer journey. This is backed through a dedicated team who focus on customer experience, along with our product governance function which continually monitors product performance and fair value assessments, and an “at least” annual product review process to ensure our products remain relevant and fit for purpose.

Most of the Stage 2 analysis work has been completed, with some final pieces of data being worked on with third parties to complete the customer journey and sludge process reviews.

A second round of analysis is due from Harris research on customer communications in March. The current view from the first stage is that our communications should be able to be understood by our customers and that the research findings will help us to implement a staged approach to make enhancements at the next available opportunity, as opposed to needing to rectify any immediate concerns. 

Next steps on project work

	Activity	Summary
1	Management information	Finalise all metrics to monitor performance through all customer touchpoints Identify any gaps in current outcomes monitoring Construct reports and dashboard for us in governance forums Embed review and discussion within relevant forums and committee meetings
2	Customer communications	Receive final Harris research finding results Pending results from research initiate schedule to add enhancements to the communications at next opportunity
3	Vulnerable customer policy changes	Enhance our expertise by appointing a vulnerable customer champion for each business function Clarify training opportunities to support our expertise Identity further opportunities to encourage customers to speak to us about their vulnerabilities Formalise the recording of customer vulnerabilities and enable reporting Develop implementation plan to update VCP changes as required Roll out additional training to wider team and embed VCP into all aspects
4	Distributor changes	Identify any changes required for our distributors based upon other workstreams Notify distributors of required changes and communicate any new expectations (30 April deadline
5	Product reviews	Complete review of product documentation to incorporate any new Consumer Duty requirements. Embed any process changes to become business as usual for future product reviews
6	Product governance policy changes	Review of Assurant Product Governance Policy document and apply changes as appropriate
7	Training	Identify ongoing requirements to embed Consumer Duty requirements into each business unit Create training package to ensure all areas are trained Roll out training program

Governance and oversight

• Working group of subject matter experts in attendance in all relevant meetings and workshops
• Steering committee to meet monthly to discuss progress
• Monthly updates delivered to UK Business Committee meetings
• Compliance audit to begin in Q2 to establish how well we have implemented the Consumer Duty change requirements

Collaboration

Throughout 2022 we completed all product reviews in line with the fair value assessments. Product review documents were all completed, along with a Distributor document which provided a summary on the fair value assessments, target market, product design etc.

These reviews and documents will be redone this year to ensure we continue to deliver products that provide fair value for the customer and will be sent through to all distributors during 2023.

We are comfortable in our progress that we will be able to advise distributors of any changes that we will require (if any) of them by the 30 April deadline.

If you would like to review any of our previous work on fair value, any further details around the Consumer Duty workshops completed, or any questions let us know and we will aim to provide anything quickly. 

What do I need to do next?

Nothing for the moment, we will be in touch before the 30 April deadline with any changes that we may need you to make by the end of July delivery date.