In our experience, the best approach is to avoid perceiving the new duty as a tick-box compliance exercise. Instead, firms should see it as an opportunity to better understand customers' needs, to empathise with their situation and priorities, and to integrate good outcomes into their everyday activities. There are significant opportunities to drive growth, enrich customer engagement and improve customer retention as a result.
The support EY has provided to clients varies according to the size, nature and complexity of each business. One global bank was keen to achieve consistency across multiple service lines, while a major UK retail bank wanted to focus on the customer suitability of a key product line. In contrast, a leading wealth manager was seeking to sharpen its customer focus across the business.
From working closely with C-suite executives, we have created collaborative teams that bring the relevant knowledge from product development, customer insight, data and technology, people advisory, and risk management. Our clients value our regulatory insights, industry knowledge, proven transformation skills and practical approaches. EY teams tailor recommendations to each client’s customer base and business, applying solutions that give early assurances and generate confidence.
There are a number of examples on these engagements, including:
Interviewing the heads of key workstreams to assess the overall consistency and quality of implementation. Focusing on interactions with senior leaders across the organisation has enabled us to quickly identify potential areas of risk and tailor work programmes to better measure and monitor customer outcomes.
Assessing the performance of key product lines, such as current accounts, or core activities, such as wealth advice, against the four key outcomes. This includes using industry standards to validate internal expectation levels.
Testing key customer journeys for a variety of customer personas, including the use of mystery shopping reviews. This has supported EY clients to broaden their customer perspective, identifying touch points that could create risks for different customer groups. It has also helped them understand how the duty impacts governance throughout the product lifecycle, and to leverage those insights across their portfolios.
By making sure to use data to consider things from a customer perspective, rather than its commercial materiality, and bringing together your different data sources to get a clearer understanding of the customer and their needs, it is possible to significantly enhance outcome testing and its usefulness in delivering good outcomes for customers. Using technology to help deliver real-time customer experience monitoring to demonstrate that their products and services are delivering good outcomes.
The ultimate aim for firms is that when the time comes to attest, senior management should feel confident they can demonstrate that they are delivering good outcomes for their customers. EY teams have provided clients with practical guidance and support, assuring them they are taking the right approach by effectively prioritising key risks and actions.