Lessons learned from Consumer Duty implementation – insurer views

“I think in terms of material shifts and changes in adviser behaviour that insurers see, it’s probably going to take a bit of time for that to actually feed through because we need to see that change in behaviour being realised put into the differences we’re seeing in terms of product mix and things like persistency and whatnot moving forward. One of the critical things that we’re so supportive of and come up a number of times in the conversations and also in the chat, is the need to write and refer. I think longer term, that’s going to result in such advantages for the industry because naturally, you’re going to get an increase in the number of individuals and families protected.”

“I think what it’s also going to do is bring into focus products that are more focused on quality as opposed to price. Again, that will bring along a greater appetite for people to actually need the support of services like Protection Guru Pro to substantiate their advice. But I think from an insurers perspective, it’s very much in the early stages in terms of seeing that behaviour actually come through… a lot of the effort has been put into reviewing and updating policies and procedures, enhancing reporting lines just to make sure that we are monitoring and capturing all the information that we need to meet our obligations, but also identify these concerns at the earliest possible stage and act accordingly.”

“I think overall, we’re in a good place, but there’s going to be a lot of learnings that are going to be taken as the months and years go on in respect of what we’ve done. I think one of the key things that we had to do was update our product development process for the consumer duty… We’ve also done quite a lot of work on our product review and fair value assessment outputs just to try and make them as robust as possible. We continuously take on feedback from advisers.  

“We’ve actually rolled out empathy training to quite a lot of our customer-facing staff. So this includes our claims guys as well. This has been incredibly well received… there’s lots of stuff that we’re doing in terms of people with physical vulnerabilities, financial vulnerabilities and the ability to identify those and provide them with the right options and signpost them to other services or their advisor at the right time.”

“We’ve definitely done some work on improving communications around supporting customers in financial difficulty. We’ve got a dedicated area of the website to let members know what to do in those circumstances.”

“Anniversary letters and indexation. That’s high on the agenda at the moment in terms of industry topics. I think that’s really important. We’re working on our own anniversary letters right now around that point so that customers know they can defer indexation as many times as they feel they need to… We made a couple of product enhancements at the end of June.”

“A few members of our team filmed some videos earlier this year that explain in layman’s terms what the insurance products we sell are. We’ve made them nice and prominent on the customer section of our website. But if a customer falls onto our website, we thought it was important that we have some easy explainer videos that say, ‘What is this? When does it pay me? Am I, am I the right sort of target for it?’”

“We’ve seen an increase in advisers using our tools and calculators to justify their recommendations. We have an income risk calculator which helps establish the need for income protection and visualise what life would look like if clients had to rely on statutory sick pay. That’s been really popular and we’ve just upgraded that as well so that it can be co-branded with advisor details that’s been really well received.”

“I look at protection slightly differently in that I face into the holistic market. So looking after advisors that historically would be doing pensions and investment business rather than protection. What’s been really, really interesting to see throughout this year is that the conversation has changed quite drastically, I would say, and the willingness for holistic advisors to entertain the protection conversation. What does that look like within their firm? How are they interacting? What does a fact find look like? How are they presenting protection propositions to their clients? There’s a lot of upskilling to be done with the advisors that haven’t sold protection for a long period of time.”

“We utilise infographics or images for critical illness and whatnot. Because again, when you look at vulnerabilities within customers, we’ve got financial vulnerability, i.e. they need for protection, we’ve got emotional vulnerability and added value benefits, etcetera, but we’ve also got vulnerabilities where we need to have large text, we need to have literature that has a reading level that everybody can understand. We need to have sales aids in different languages because we face clients where English isn’t their first language. So we’ve delivered that and have had that for quite some time to enable us to really help advisors maximise the understanding with their customers to showcase that actually they have ongoing support. They’ve got an understanding of the product, the features, the benefits and what is it they’re being advised on and something that they can easily ascertain and understand exactly what it is they’re being advised on.”

“we need to look at how can we interact with advisers, particularly those who are re-entering a protection market. For some of the younger advisors, it’s brand new and how can we get them in contact with underwriters as quickly and efficiently as possible? So we’ve developed things like guides. Not only does it give them information on sort of top 25 definitions that we see as a provider, it tells them the kind of information that we need to gather to underwrite. So it’s ticking the box so that they can go and ask the right questions. It gives them potential outcomes.”