The Financial Conduct Authority says customer communications must be understandable and facilitate informed consumer decisions, as well as ‘clear, fair and not misleading’.
The Consumer Duty requires firms to proactively develop the evidence that their communications and documents are designed accordingly.
In the Consumer Duty Guidance, the FCA used Fairer Finance as an example of the external support and guidance available to firms wishing to achieve consumer understanding (FG22/5, para 8.35).
Drawing on our expertise is cited by the FCA as a key way to improve consumer understanding: "Firms may wish to consider external support and guidance available on how [consumer understanding] can be achieved, such as Fairer Finance’s work on readability." (Consumer Duty Finalised Guidance, para 8.35).
Trade bodies, such as the Association of British Insurers, the Building Societies Association, and the Equity Release Council have asked Fairer Finance to develop practical guides for their members on writing good customer communications.
We have a firm grasp on best practice across financial services sectors. We analyse hundreds of terms and conditions, policy documents and online customer purchase journeys, every six months - as part of the research that underpins our unique customer experience ratings.
We work with companies to make their communications clearer - from a language, structure, and design perspective. Our expertise is sought on T&Cs documents, brochures and policy documents, emails and letters, and online customer journeys.
With objective and defined criteria, our Clear and Simple Mark has become the industry standard for good communications. Our criteria are publicly available on our website and through our work with trade bodies. It is hard to achieve the Clear and Simple Mark - and doing so is good evidence of well-designed communications under the Consumer Duty.
We go beyond just pointing out what is unclear or complex. We work with you to develop better ways of communicating – identifying and implementing the solutions. We know the FCA’s sector-specific disclosure rules inside out. We know when a certain wording is required, and when it is not.
We don’t just write good copy. Our team of industry experts understand the nitty gritty of your markets and products, across retail financial services. We guide you on what information is ‘must know’, ‘should know’, or ‘nice to know’ for your customers to make informed decisions.
Providers ask us to support their teams in three ways.
Providers ask us to rewrite their communications from scratch. We start with a new structure and deliver a full draft – with the entire communication meeting the stringent Clear and Simple Mark criteria. We then hold a series of challenge sessions with your internal stakeholders to discuss concerns and work towards a final draft that is clear for customers but also protects the company. The final result is a document that is awarded the Clear and Simple Mark.
We are thoroughly impressed with the Consumer Understanding assessment that Fairer Finance carried out for us. Their attention to detail, thoughtful recommendations and commitment to excellence have made a positive impact on our business and we would highly recommend their services.
Firms ask us to advise their teams in the process of rewriting their communications. We begin by providing a new draft structure for the communication, helping order the information in a more intuitive way for customers. Then, once a first draft has been delivered to us, we mark up the draft with detailed suggestions for improvements. Crucially, we then hold at least one challenge session with key stakeholders from the legal and compliance departments - and also from underwriting and claims in the case of insurance. Where applicable, the final result is a document that is awarded the Clear and Simple Mark.
Providers ask us to analyse and highlight issues in their communications. We outline our framework – using examples – and assess the document(s) on a 5-point scale. This is a measure of how fit for purpose they are in relation to the Consumer Duty. A score of ‘5 – Excellent’ on this scale is equivalent to achieving our Clear and Simple Mark.
We chose to work with Fairer Finance on Consumer Duty projects due to their wealth of knowledge and experience in the financial services sector, including governing bodies obligations, which made them the ideal partner.
We hosted a webinar in January 2024 that covered how to write, design and test clear and simple communications.
If you'd like to discuss how we can help with rewriting your communications, drop us a line.