Consumer Duty – Meeting a higher standard

Financial planning system Dynamic Planner has intrinsically supported good client outcomes for two decades. Its mission today is unchanged from its 2003 launch: matching people with suitable portfolios through engaging wealth and financial planning.

Learn more about how Dynamic Planner can help you meet Consumer Duty standards below.

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The Consumer Duty aims to raise standards of consumer protection across
financial services and to prevent harm, underpinning the regulator’s 2022-25
strategy. The FCA has characterised the Consumer Duty as ‘customer-centric’.
Are products and services designed to deliver good client outcomes?

You have had to plan how you are going to achieve all of this, but, for open
products and services from 31 July 2023, thinking significantly shifts to
delivering it. How do you do that? Echoing the Duty’s cross-cutting rules, how
do you take all reasonable steps to avoid foreseeable harm to your clients;
enable them to pursue their objectives; and act in good faith?

Download our brochure to learn more about how Dynamic Planner can help you to meet Consumer Duty standards with one financial planning system.

Consumer Duty FAQs

What is the Consumer Duty?

The Consumer Duty’s overarching Principle requires firms to act to deliver good outcomes for retail customers. Three cross cutting rules, providing greater clarity on FCA expectations here, require firms to:

  1. Act in good faith towards retail customers
  2. Avoid foreseeable harm
  3. Enable and support retail customers to pursue their financial objectives

What outcomes does the FCA want to see?

Under the Consumer Duty, the FCA has highlighted four outcomes to help drive good outcomes. They relate to:

  1. Products and services
  2. Price and value
  3. Consumer understanding
  4. Consumer support

At every step, firms are required to consider the needs, characteristics and objectives of their clients, including those with characteristics of vulnerability. Furthermore, firms will need to understand and evidence whether outcomes are being met.

What does this mean for me and my firm?

Changing the culture at your firm, so that you can be confident that every person and process is meeting the Consumer Duty. Additionally, can you evidence everything which has been implemented, to place your clients and good outcomes at the heart of your business?

How can technology support me?

For 20 years, Dynamic Planner has been focused on the client outcome. Not the product search. In an advice firm’s hands, it fundamentally enables clients to achieve their financial objectives. Post-2018, it has been rebuilt to meet MiFID II and PROD, with one vision of a client being happy at every review. It naturally aligns to the Consumer Duty.

It is a complete financial planning system. Within it, you can confidently match an investment solution to a client, or a group of clients, without having to leave. The audit trail it evidences too is complete.

With the support of technology, how can you satisfy the Consumer Duty’s three cross-cutting rules? Firstly, act in good faith?

Dynamic Planner focuses on the client and their outcome, not the product and its latest market position. As a business, it does not compete with its clients, in the market it serves them.

Commercial influence does not impact Dynamic Planner’s research analysis, risk ratings or outputs. Additionally, the system has governance, oversight controls, checks and balances, alongside three lines of defence mechanisms, to manage out bias and conflict of interest.

Avoid foreseeable harm?

Dynamic Planner enables you to understand your client’s risk tolerance and vulnerability. It uses behavioural science positively to support your client’s understanding, and manage out cognitive and behavioural bias, which can be exploited and can lead to harm.

Dynamic Planner only enables mainstream investments, in line with the FCA’s Consumer Investments Strategy. Market, liquidity credit and the ESG risk of solutions and portfolios are calculated at instrument level and reported. Dynamic Planner’s ‘reasonable assumptions based on objective data’ cannot be manipulated. 

Enable and support clients to pursue their financial objectives?

Dynamic Planner places your client’s needs, objectives and characteristics foremost, and their financial plan front and centre. It enables you to capture objectives in a client’s own words. Goal-based and lifetime cash flow planning is accessible for all types of financial planning firms and clients. 

Clients and their financial plans can be reviewed frequently and at scale, with advisers able to service 500 clients a year. The provision of a digital application for your clients, tailored to your brand and voice, extends your capability to enable and support them.

With the support of technology, how can you deliver the Consumer Duty’s four outcomes? Firstly, the governance of products and your services?

Dynamic Planner is designed so that a firm can only perform a function for either an individual client or for a defined target market of clients. Within Dynamic Planner, you can confidently match an investment solution to a client or target market without leaving the system. The audit trail it evidences is complete.

Client-focused product features, alongside the advantages and disadvantages, enable the same language to be used in your product governance and your suitability disclosure. Meantime, the connection from the consumer needs, to the manufacturer, product governance and the advice process is seamless, and consistent with a circular audit trail.

Price and value?

Categorising solutions by risk and preference enables you and a client to properly identify fair value among suitable investments solutions of comparable nature, quality and benefits. Objective standards and benchmarks enable price and value to be calculated and demonstrated. 

Also, the Dynamic Planner experience and output is itself of value to your client. It elevates the value your firm provides, and value that is often missed. Dynamic Planner’s efficient processes increase the time you can spend on client engagement and understanding. In brief, what you do best, enjoy the most, and what your clients arguably value most.

Consumer understanding?

Dynamic Planner increases the focus on your firm’s clients, ensuring that they understand communications that they receive from you. The overall quality of communications Dynamic Planner enables firms to produce means that your client is more likely to engage with, receive and remember the advice.

Within communications, a client’s story flows from start to finish, without the need to switch documents, applications or terminology. In support, Dynamic Planner’s behavioural science team conduct original academic research to ensure key analysis in the system is understood, while Dynamic Planner’s risk profile descriptions are approved by the Plain English Campaign. 

Consumer support?

Dynamic Planner enables efficiencies in the financial planning process and supports your client in making effective, timely and informed decisions. Investment solutions, communications and services are matched to target markets of clients or individual clients, so that you can anticipate future challenges they may meet and mitigate them with the right solution. Moreover, Dynamic Planner’s methodologies are backed by supporting material from experts.