What connects broccoli, AI and good practice? Reflections on the FCA review and our work with firms

The FCA is spitting out insight for firms quicker than my son spits out his broccoli, this time looking at how firms monitor outcomes as part of the Consumer Duty. The big difference being that the FCA sharing its insight is helpful – and doesn’t require a J-cloth.

But, if like me, you’re barely keeping up, I imagine you won’t be in a position to read a ‘review of the review’. So instead, I’ll reflect on just one thing based on the work we do at Money and Mental Health, and then I’ll shut up about it. Hopefully this reflection will help firms better understand one area of the outcomes monitoring review in a bit more depth and what a difference getting this right can make.

One section of the FCA’s review describes a firm using customer feedback and operational insight to improve its in-app chat service. By introducing AI to complete keyword recognition, it was able to identify potential indicators of vulnerability, route customers to the right support team more quickly, and significantly reduce response times.

It’s a great example of good practice that took me back to a mystery shopping exercise we carried out as part of a Mental Health Accessible assessment. But before I share that, I want to reflect on the FCA’s reference to ‘AI’ being used for keyword routing. 

For many people, ‘AI’ immediately brings to mind the recent explosion in interest in generative AI. But the capability the FCA is describing is much more likely to fall into the category of natural language processing, keyword recognition, or rules-based and machine-learning routing – techniques that have been used in customer service and contact centres for well over a decade. 

That’s one reason I want to share the exercise below. As good as the FCA’s example is, it has to remain relatively high level. I hope the example below helps illustrate the value of testing and reviewing whether the improvements firms are making are actually being experienced by customers – particularly the complexity of what creates a good outcome for customers with mental health problems.

After years of working with a bank across a range of customer journeys (including its in-app chat), we tested this journey ourselves following iterations from the firm. Our mystery shopper explained they were struggling with their mental health and that it was affecting their spending. During the conversation, they disclosed a mental health problem.

Within around a minute, the chatbot recognised what had been shared and routed the customer to a member of staff. The adviser immediately acknowledged the disclosure, responded with confidence, empathy and reassurance, and asked open questions to better understand the customer’s circumstances before explaining that a specialist team would be best placed to help.

When the shopper explained they weren’t comfortable using the telephone, the adviser didn’t simply repeat the process or ask them to call anyway. Instead, they adapted the journey and transferred the conversation directly to the specialist team through the same digital channel.

What followed was one of the best examples of customer support I’ve seen during my time working on our Mental Health Accessible programme.

The specialist adviser took time to understand the immediate risk of financial harm before exploring the shopper’s wider circumstances. They discussed practical ways to manage spending, talked through tools available on the account, and explored whether the customer was already receiving support elsewhere. They also signposted appropriate mental health support, explaining how approaches such as cognitive behavioural therapy could help address the behaviours contributing to the customer’s spending. The conversation ended with warmth, encouragement and an invitation to come back if more support was needed.

There was so much to praise. The vulnerability was recognised quickly. The customer didn’t have to repeat their story. The journey adapted to meet their communication needs rather than expecting them to adapt to the bank’s process. The support addressed both the immediate financial risk and the wider circumstances driving it. Most importantly, the interaction felt human.

Back to the FCA review, it also highlighted the other side of the same coin. The FCA shared examples where firms had identified friction in customer support and introduced improvements, but customers were still experiencing many of the same problems.

In one example, a firm had made changes to improve its LiveChat service, but customers were still being passed between advisers and complex issues weren’t always resolved the first time. 

It’s a helpful reminder that introducing improvements isn’t the same as knowing they’re working.

That mystery shop is just one example of the hundreds of pieces of work that sit behind our Mental Health Accessible programme. Everything we do is rooted in the lived experience of people with mental health problems twinned with research and policy expertise, helping firms understand what their services look and feel like across the customer journey, not just at the end (another area that came through in the FCA review).

Alongside this, we provide critical feedback on monitoring frameworks that compare the experiences and outcomes of customers in vulnerable circumstances with those who are not. This includes more detailed analysis of specific groups, such as customers with known mental health conditions compared with those without. Crucially, we also help ensure that those analyses lead to meaningful action, rather than changes that don’t address the root problem, so firms can respond to current harms and reasonably prevent foreseeable harm.

Everything we do is in support of our mission to break the link between mental health problems and financial difficulty – a mission I care deeply about.

If you’d like to talk about the work we do through Mental Health Accessible, or anything else that came through in the FCA’s review, we’ve got plenty to say about it. But I’ve committed to shutting up and I have some more half-chewed broccoli to stick in the compost… so I’ll stop there, but please get in touch – our email is [email protected].