Alexis Stevens, Senior Strategic Partnerships Officer, Money and Mental Health Policy Institute
Firms should put customers with lived experience at the heart of Consumer Duty plans
3 October 2022
I’ve been at lots of events recently with essential services firms, focused on how best to support customers through the difficult times ahead. Some of these have unsurprisingly focussed on the Financial Conduct Authority’s new Consumer Duty — which sets clearer standards of consumer protection across financial services — and requires firms to put plans in place by the end of October this year.
During these events I’ve heard some seriously innovative ideas, and seen genuine commitment from firms to make a difference for customers, deadline or not.
But I felt that there was one key concept that deserved greater focus in these discussions: the importance of firms including the voice of people with lived experience of mental health problems and other vulnerabilities at the heart of their Consumer Duty plans. This is critical if firms are to truly improve outcomes for consumers. The Duty is, after all, aimed at protecting them and ensuring they get a fairer deal.
How we can help firms
The Consumer Duty is a step in the right direction – our research has consistently shown that people with mental health problems are at greater risk of poor outcomes – but we do recognise this represents a huge task for firms.
That’s why over the coming year, experts in our Mental Health Accessible team are working on programmes with five leading banks that will support them in meeting the Duty.
In particular, we will provide firms with the opportunity to hear from our Research Community – an engaged group of almost 5,000 customers with lived experience of mental health problems – about what works, what doesn’t and how they can better support their customers.
Different challenges for different banks
We know from our work with firms that a challenger bank with nifty tech faces very different challenges to an established building society with complex, legacy systems.
But for all firms, involving customers with mental health problems in Consumer Duty plans is both crucial and strategically savvy — regardless of whether you are considering how to meet Duty requirements regarding the roles and responsibilities within the distribution chain, making decisions around the collection and use of data, or answering difficult questions about resource and demand.
That is because there’s a huge prevalence of mental health problems in every firm’s customer base:
- Over half of UK adults say they have felt anxious as a result of higher prices during the cost of living crisis
- Half of people in problem debt will also have a mental health problem
- Many of the challenges faced by someone with mental health problems can be similar to the challenges posed by other cognitive conditions and learning disabilities. That means focussing on mental health problems is an effective path-finder that could have a positive and wide-reaching impact on consumers with other vulnerabilities – and all customers more generally.
Our Mental Health accessible team provides bespoke consultancy and insights that can help shape your Duty implementation plans, on areas such as:
- Digital accessibility, including identifying things like good friction and sludge practices, (defined by the FCA as ‘an excessive friction that hinders consumers from making decisions in their interests, by taking advantage of their behavioural biases‘)
- Improving complex or sensitive communications
- product design and considering frameworks that prevent foreseeable harm
- our flagship programme, the Mental Health Accessible accreditation, which Lloyds Bank, Halifax, and Bank of Scotland hold.
If you work in a bank or building society and are tasked with progressing its Consumer Duty implementation plan, you have a big opportunity to get it right for vulnerable customers. And the sooner firms get it right, the faster we can disrupt, and break, the vicious cycle of money and mental health problems.
We’d love to help your team with all or any of the above, if you’d like to learn more, reach out to us at [email protected] .