Fulfill Consumer Duty by Realising the Value of Conversations Build a bulletproof Consumer Duty implementation plan with AI and automation.

Fulfill Consumer Duty by Realising the Value of Conversations Build a bulletproof Consumer Duty implementation plan with AI and automation.

Kumaran ShanmuhanBy Kumaran ShanmuhanVice President, Industry SolutionsUniphore
9 min read

Consumer Duty is Good for Business

Customers are losing trust in banks and financial services firms and see them as interchangeable with new entrants who are disrupting the space and taking customers and profits away from traditional financial institutions.

To regain customer trust and grow market share, firms should get back to basics and do right by the customer. In the United States, the Consumer Financial Protection Bureau (CFPB) has made it clear that financial institutions must protect the interests of consumers. Meanwhile, in the United Kingdom, the Consumer Duty unveiled by the FCA represents a paradigm shift in regulator’s expectations of financial institutions.

Though there are a variety of challenges in achieving this higher standard of customer protection, market leaders can leverage these regulatory requirements as opportunities to strengthen customer relationships and enrich brand loyalty. When we look at it through a business lens, it doesn’t matter whether your firm operates in the UK, the US or Australia; and regardless of whether the Consumer Duty applies to your firm, you’ll see that these consumer duties are just good for business. Let’s explore how AI and automation can help you not only comply with regulatory requirements, but also win the trust and loyalty of your customers.

What is Consumer Duty?

Before diving into the role of AI and automation, let’s offer a quick Consumer Duty summary. The Financial Conduct Authority (FCA) in the UK introduced a new set of requirements that went into effect 30 April, 2023. In recognition of the barriers many consumers face to pursuing their financial objectives, the FCA wants to see firms deliver a higher standard of customer care and protection and to go further to equip consumers to make effective decisions in their interests.

The Consumer Duty introduces a new Consumer Principle, which requires financial institutions in the UK “to act to deliver good outcomes for retail customers.” This outcome-focused approach revolves around four key areas of the customer relationship:

Governance of products and services

Price and value


Consumer support

State of Consumer Duty Compliance

The FCA’s Consumer Duty is leaving organisations scrambling to ensure timely compliance as they head towards the July 2023 deadline. The new regulation requires organisations to think beyond simple rule book compliance and take a holistic and technological approach to ensuring that their customers receive good outcomes. 

With the 31 October deadline for approving implementation plans now past, a staggering two thirds of banks and building societies did not feel confident that they were compliant.

FCA Consumer Duty Leaves No Room for Misconduct

This increased pressure follows the announcement that fines issued by the FCA for misconduct almost tripled in 2022*, sending a clear message that it is “back in business” post-pandemic, whereby some regulatory initiatives were offered leniency. It also follows a year where mistreatment of retail customers across financial services was vast, ranging from the poor treatment of customers in guarantor loans to poor advice regarding pension transfers and self-invested personal pensions.

This news has further heightened the urgency of the Consumer Duty, and the FCA has said that it is determined to protect consumers whose financial stress during today’s cost-of-living crisis might lead them to making unwise decisions in terms of investment or borrowing.

Proving the “Customer-First” Mindset is an Uphill Battle

Consumer Duty has been hailed as a game-changing regulation for firms as the FCA moves to data-first supervision and expectations of risk assurance and quality fundamentally shift. However, organisations across the board are having real challenges creating implementation plans, validating definitions of the “good outcomes” the duty requires and proving evidence of appropriate action, support and compliance.  Even more alarming is that one in ten decision makers said they aren’t even aware of the new regulation despite a deadline that has loomed since November.

From What to How? Here Are the Key Deadlines You Need to Know.

The FCA expects Consumer Duty compliance to be an iterative process due to its wide-ranging scope. While there is not a one-size-fits-all approach, firms are expected to have “substantive” compliance from day one of the 31 July implementation deadline. In what is considered as a complete change in mindset and not just rule-book compliance, the FCA also warns that firms need a longer-term view and should challenge themselves to continuously review their processes to improve and deliver better outcomes for customers.

2 in 3

With as many as two thirds of lenders not yet compliant just before the holiday break, there is still work to be done ahead of the deadline.  

The Final FCA Consumer Duty Deadlines Are as Follows:

  • 30 April 2023: Manufacturers should have completed all the reviews necessary to meet the outcome rules for their existing open products and services so they can share with distributors to meet their obligations under the duty and identify where changes need to be made.
  • 31 July 2023: Implementation deadline for new and existing products or services that are open to sale or renewal.
  • 31 July 2024: Implementation deadline for closed products or services.

The Impact of Technology on Consumer Duty Implementation Plans

Conversational intelligence tools, including conversational AI and automation, are making it easier for businesses to design and deploy an effective Consumer Duty implementation plan. However, despite this, only 43% of firms are planning on using technology to access customer data and insights to adhere with the Consumer Duty regulation. Financial institutions who intend to make do without the help of conversational analytics, artificial intelligence and automation technologies are in for a tough road ahead.  

Banking on Trust: Go from Chasing Complaints to Building Trust in Every Customer Interaction

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Fulfill Your Consumer Duty in Four Simple Steps

In the scramble to roll out a Consumer Duty implementation plan, AI-enabled businesses have a clear advantage over their unenabled peers. For businesses looking to get up to speed quickly, here is sample, four-step plan for leveraging conversational AI and automation to ensure that your Consumer Duty implementation plan succeeds. 

Measure What Matters with Pre-trained AI and Advanced Analytics 

The FCA suggests that firms track the following data points to measure how they are driving customer outcomes.

Customer Churn Analysis

Product Sold, Pricing & Fees By Customer Segment

Cross-Channel Customer Journey Insights

Staff Training & Proficiency Levels

Staff Performance, QA, Coaching Insights

Feedback from Customers, Partners, and Staff

Customer Complaints

With conversational AI, businesses can gather all relevant datasets more accurately and efficiently than through surveys and/or manual conversation analysis. That’s because AI can listen to 100% of every call and capture what matters—completely, consistently and impartially. What’s more, with today’s high-quality voice and metadata capture capabilities, organisations can have instant access to customer interaction data across the enterprise.

Why does that matter? Because even though many organisations can access their data, only a few are utilising it to glean insights into customer outcomes. At Uniphore, we offer predefined solution packs that already look for these aspects, including complaints by topic and sub-topic with an additional dissection of support for vulnerable customers. These solutions can help any financial institution measure what matters—and make meaningful decisions and actions based on that data.

Using our pre-trained AI models, firms can quickly conduct a gap analysis by analysing customer interactions to highlight any areas where processes do not meet Consumer Duty requirements.

Engage in Root Cause Analysis Using Actionable Insights 

AI can help organisations perform more effective and – by accurately and automatically—classifying an issue. By assigning classification and analysis tasks to machines (instead of error-prone humans), financial institutions can create a smooth, closed-loop complaints management process that minimises escalations while improving resolutions and compliance with Consumer Duty regulation. Here’s how AI and automation can improve root cause analysis with regards to Consumer Duty guidance: 

Understand vulnerable customers: Ensure the fair treatment of vulnerable customers by capturing, monitoring and addressing issues as they emerge. This provides you with a better understanding of how vulnerable customer requirements change over time to drive service and product improvements.

Support your agents: Nurture and coach agents with targeted insights and learn from your highest performing agents. Score each agent and team based on the agent’s impact and on-the-call difficulty, and provide succinct, actionable information that tells you what your call center team is doing right—and what support is needed to fix it. 

Demonstrate compliance: Moving from person-centric supervision to data-first evidence, use dashboards to demonstrate an improved understanding of customer outcomes, the factors that affect them over time and what remedial action has been taken, so you are ready for the regulator. 

Improve complaints handling: Understand the cause of customer complaints and not just the symptoms by using voice data to measure customer satisfaction, risk, agent behaviours and identify areas of friction in the customer journey. These insights can drive business outcomes, such as improved customer loyalty. 

Listen to every interaction: Get a score on 100% of customer conversations. By monitoring all interactions—regardless of channel—firms will be able to see which form of communication is most effective and make better decisions on the way they interact with customers, which meets Consumer Duty expectations. 

Boost your QA processes: Utilising rich audio and metadata, configure chosen sets of conversational data, playback audio for accurate analysis, and track how your QA efforts are positively impacting your Consumer Duty obligations to significantly improve QA efficiencies  

Prevent Issues with Real-time Agent Assist

With real-time agent assist, you can implement changes to standard operating procedures and ensure that your staff learn on the job and fulfill your responsibilities for driving the desired Consumer Duty outcomes. Combining advanced, real-time agent guidance with data-rich post-call summarisation—all in an intuitive user interface—Uniphore’s agent assist solution, U-Assist, can turn every contact center agent into a Consumer Duty champion. Here’s how:

Educate staff on products, terms, conditions, pricing and fees so that they can answer questions and explain in simple terms to the customer the cost and benefits of the offer.

Offer real-time empathy coaching for staff on how to manage the conversation better based on the customer’s sentiment and tone (e.g., hesitation, confusion, etc.)

Impart financial wellness tips aligned with the customer’s objectives using knowledge AI instead of incomplete (or incorrect) employee expertise.

Detect customers in vulnerable situations using AI and deliver coaching for staff to help them sensitively. 

Coach staff in real-time on what constitutes aggressive selling and share best practices while preventing behaviour that might lead to negative customer outcomes.  

Capture implicit customer feedback on product fit, fair-value concerns, understanding related issues and consumer support challenges among other topics, and classify the complaint with automated conversation summaries. 

Monitor for Improvement Opportunities 

By identifying opportunities for optimisation, AI can drive higher efficiency in several key areas. For example, Uniphore’s no-code/low-code platform and pretrained AI solution packs can help firms cut time to value by as much as 60%, launch the solution in production in weeks and scale it for both customers and employees who can drive material customer outcomes. By monitoring for improvement opportunities, running experiments and scaling the customer protection mindset across the organisation, AI and automation can not only help organisations comply with FCA Consumer Duty regulation—they can generate real value in customer satisfaction, loyalty and trust.  

Banking on Trust: Go from Chasing Complaints to Building Trust in Every Customer Interaction

Download Now

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