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.

For more information and advice on Consumer Duty read this next:

Author: Guest Author
Reviewed by: Megan Jones

Published On: 18th Jan 2024
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