6 Steps to Navigating Consumer Duty Closed Book Implementation

checklist and gavel with the words Navigating Consumer Duty Closed Book Implementation

In the ever-evolving realm of financial services, the 2024 implementation of Consumer Duty Closed Book regulation presents a considerable challenge.

For leaders in contact centres, comprehending and effectively managing the impact of this implementation is crucial to guarantee compliance and deliver positive customer outcomes.

James Edmonds, Director of Investor in Customers Ltd, explains how to succeed in these 6 key steps:

1. Inventory and Definition – Setting the Foundation for Compliance

As the backbone of customer interactions, contact centres will play a pivotal role in the Consumer Duty Closed Book implementation process.

Leaders must collaborate closely with compliance teams to identify and define legacy products accurately.

This is essential for streamlining customer interactions related to closed products and maintaining consistency in aligning with regulatory standards.

2. Performance Assessment – Tailoring Measurement Strategies for Closed Products

Traditional metrics such as Net Promoter Score (NPS), Customer Satisfaction (CSAT), or retention might not provide a comprehensive understanding of closed product impacts.

Contact centre leaders should advocate for a bespoke Four Outcome measurement strategy to assess customer experiences accurately and ensure regulatory compliance.

3. Product Profiling – Enhancing Customer Understanding for Informed Interactions

Contact centres thrive on data-driven insights. Profiling closed products involves assessing closure rationale, materiality, ongoing governance, customer activity, and more.

Leveraging this information allows contact centre leaders to guide their teams in delivering informed and customer-centric interactions.

4. Strategic Decision-Making – Impact on Customer Interactions

Understanding the firm’s approach to treating closed products is paramount for contact centre leaders.

Whether it’s keeping and repairing, implementing tactical solutions, migrating, closing, merging, or selling, leaders must align contact centre operations to these decisions.

This ensures that customer interactions remain consistent with the firm’s chosen strategy.

5. Implementation Planning and Prioritization – Aligning Contact Centre Operations

Revisiting implementation plans is a collaborative effort between compliance and contact centre leadership. It involves prioritizing actions, addressing competing priorities, and managing resourcing challenges.

Lessons learned from open product implementation should be integrated into contact centre training and operations.

6. Ongoing Governance and Risk Appetite – Sustaining Compliance in Contact Centre Operations

Ensuring ongoing compliance requires contact centre leaders to embed detailed closed product analysis into governance structures.

Engaging stakeholders and aligning operations with the firm’s risk appetite are vital for sustained compliance.

Remaining agile in response to emerging regulatory perspectives post-July 2023 is key to adapting contact centre strategies.

Contact Centre Leaders Play a Critical Role in Successful Implementation

James Edmonds, Director of Investor in Customers Ltd.
James Edmonds

Contact centre leaders play a critical role in the successful implementation of the Consumer Duty Closed Book in 2024.

By understanding the nuances of closed products, tailoring measurement strategies, and aligning operations with strategic decisions, contact centres can not only meet regulatory requirements but also deliver exceptional customer experiences in this evolving regulatory landscape.

Written by: James Edmonds, Director of Investor in Customers Ltd.

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Author
James Edmonds

James Edmonds is the Managing Director of Duty CX, and Commercial Director at Investor in Customers and Steyning Town Football Club. He started Duty CX in 2024 to help companies in Financial Services with their Consumer Duty needs, and to help in bridging the gap between the Duty and Customer Experience.

James originally joined IIC to evolve its commercial offering, including the addition of a proposition focused solely on the FCA’s Consumer Duty legislation, while also delivering Customer Experience (CX) and insight engagements for IIC’s clients. Today, he continues to work for IIC assisting in growth and strategic development.

He has operated in CX and Strategy roles primarily in Financial Services for nearly 20 years. Having worked at L&G, RSA, More Than, JUST, James Hay and Nucleus, James has a wealth of experience. In more recent years, James has developed a specialism in interpretation of FCA regulation, enabling businesses to be both compliant, and to differentiate themselves via exciting approaches.

James’ work on Vulnerable Customer strategy has received external recognition, speaking at events on many occasions, including TISA’s Vulnerable Customer conference. Having experienced personal periods of vulnerability, James uses his experiences with service providers in these times as a professional motivator, and to help focus clients on the importance of striving to provide empathetic outcomes for their customers.

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