Oliver Crawford

By Oliver Crawford

The FCA's new Consumer Duty rules have focused the minds of providers on how to give support to vulnerable customers on their websites, and how to help users understand the advantages and limitations of their products.

The 'consumer support' requirement of the Duty calls on providers to design their online journeys in such a way that gives 'customers sufficient opportunity to understand and assess their options'. Providers are also required to take 'account of the needs of customers with characteristics of vulnerability'. These characteristics could be a physical or learning disability, low confidence in dealing with financial products, or a recent negative life event.

At Fairer Finance, we regularly mystery shop banking and insurance websites to assess both their transparency and how easy they are for customers to use. Below are some examples of good practice that have emerged recently, likely in response to the Consumer Duty.

1. Audible Terms and Conditions

A few providers, such as Animal Friends and Monzo, have begun making their terms and conditions available in audio form on their websites.

Some customers with visual impairments use screen readers to navigate websites. These don't require terms and conditions to be in an audible format — with a screen reader you can listen to terms and conditions displayed as text on websites, so long as those documents are suitably formatted. These customers might use braille versions of terms and conditions, where they are available.

Nonetheless, audible terms and conditions or policy booklets can be helpful for those who generally prefer to digest product information by listening to it instead of reading it, a group likely to include those who who find long written documents intimidating or off-putting because of learning difficulties such as dyslexia. Having audible terms and conditions was in fact mentioned by a participant in a research study we did on how to improve disclosure in the credit card sector.

2. Video Explainers

Providers are also beginning to offer videos on their websites that explain how their products work.

The Exeter - a health insurance provider - is an example of good practice here. They host several useful videos on their website that go through the workings of health insurance in terms that beginners can understand.

The challenge for both insurers and banks is integrating these videos into the online journey in a way that makes customers more likely to watch them. Making customers watch them during the check out, while their payment details are being processed, is a potential way of doing this.

What health insurance doesn't cover from The Exeter on Vimeo.

3. Increased Font Size

Having a uniformly large font size on a website makes it harder for customers to miss key product details. It's also useful for customers who have visual impairments and so struggle to read small text - especially those with poor IT skills ('low digital capability' in the FCA's terms), who may not know how to zoom in on a website.

Lloyds and Bank of Scotland have both recently increased the standard font size on their website to 18 pixels, which is a welcome change.

4. Informing Customers of the Limitations of a Product

The Consumer Duty states that providers should give customers 'information they need about the benefits and limitations of the product or service they are buying'.

Triodos, a green banking provider, has taken the step of including a table on their website showing both the features and limitations of their current account. This is a useful source of information for potential customers, since without this table they might not be aware that certain features, such as Apple Pay, are unavailable with this product. That's because information on product features is generally spread across several pages and documents. Triodos deserves credit for their transparency here.

5. Signposting Support for Customers

Some providers now have dedicated pages on their websites that direct users to sources of support for various vulnerabilities.

RBS and American Express are two examples of providers that do this, with their pages organised according to the various characteristics of vulnerability listed by the FCA, such as negative life events or health vulnerabilities.

HSBC has begun prompting users to visit the help page by having a 'Need help' button pop up while users are scrolling through the page. Some will find this helpful, if they can't find what they're looking for on the page but don't know how to navigate to the support page.

What Next?

The changes outlined in this post show that several providers are making a real effort to better inform users about their products and address the needs of vulnerable customers.

There is still much to be done, however, since online journeys remain very uneven when it comes to clarity and transparency. Some providers are innovating and adopting best practice, while others still do poorly at making their websites informative and accessible. Examples of bad practice that persist are using unreasonably small text, failing to make pages mobile-friendly, and making it too difficult to find summary documents or terms and conditions.

Our customer experience league tables are a way of encouraging providers to compete on transparency. We also work with firms to help them improve their online journeys. With the new Consumer Duty rules coming into force, and with some providers stepping up on customer support and accessibility, that work has taken on a new urgency.

Fairer Finance has a range of tools and services to help firms meet the requirements of the consumer duty. For more information contact corporate@fairerfinance.com