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Consumer Duty: the importance of trust in the age of customer empowerment

The entire world is currently attempting to manage financial downturn, and the UK has not been left untouched by this upheaval.

The International Monetary Fund project revealed that the UK’s GDP would shrink by 0.3% in 2023. In June 2023, the Bank of England raised interest rates to 5%, the highest in almost 15 years. As a result of this, different demographics are feeling the squeeze.

Home buyers are greatly impacted by these high interest rates because payments on existing mortgages have increased, and mortgage lenders have withdrawn deals. The younger generations, namely Gen Z and millennials, are also seriously feeling the pinch. Students in England who graduated in 2021 are facing an average of £45,000 in debt, according to Statista. In addition to this, pensioners have also seen their pension funds drop.

In the context of this, the FCA’s Consumer Duty Principles, which will come into full effect in July 2023 for new and existing products, is expected to set clearer standards for consumer protection across financial services. Organisations will need to deliver whilst keeping the best interests of consumers in mind. For many, the Consumer Duty Principles have come at a good time, amid financial uncertainty.

While it is evident that the Consumer Duty Principles are a step in the right direction for the financial services industry, this legislation also offers firms the opportunity to build greater trust with their customers.

Financial services firms can leverage Consumer Duty Principles to develop trust by consistently catering to the needs of different demographics, personalising and tailoring products and services to ensure the financial wellbeing of all is considered. This can be achieved by establishing a robust trust architecture through genuine transactional/non-transactional customer engagement, providing intrinsic value and transparent communications.

What are the Consumer Duty Principles?

In periods of economic uncertainty, consumer confidence in financial institutions is adversely affected. Forrester’s Financial Services Customer Trust Index reveals that financial services firms have a significant trust gap in comparison with other industries. The cost-of-living crisis has further highlighted the need for better protection, but it is important to note that Consumer Duty predates today’s economic conditions.

The aim of the legislation is to implement guidelines that ensure financial firms are prioritising the interests of their customers and provide products and services which meet these needs. Additionally, the Principles require financial services firms to communicate with customers in a clear, fair way, and ensure they avoid misleading language.

The three Cross-Cutting Rules are designed to ensure that firms put the Consumer Principles into practice. These rules require firms to:

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

Using Consumer Duty to build customer trust

Financial services firms are leveraging Consumer Duty Principles to improve their customer journey alignment through customer communications assessments and improvements; communication controls; data and analytics model refinement; controls and reporting; and complaints management from a compliance standpoint.

Alongside using Consumer Duty Principles to build their trust architecture by driving genuine non-transactional engagement with customers, financial services firms can also drive emotional engagement by focusing on a customer’s financial wellbeing. This can result in the development of a longstanding relationship between the customer and the financial services firm, leading to deeper loyalty.

Customers may not always be aware of or be able to make the best financial choices for themselves due to lack of information and understanding about products and services. Financial institutions should, therefore, prioritise customer wellbeing through advocacy and design. This requires a deep understanding of the customer and their financial behaviour and providing them with necessary information and nudges towards better decisions, which can in turn lead to financial satisfaction.

At Capgemini, we believe financial services firms need to rethink and redefine their trust architecture. Financial services firms must leverage the principles laid out by the FCA and develop various elements required to build the trust architecture. In prioritising this, firms are also consistently catering to the needs of different segments, including vulnerable groups. The different elements of the trust architecture focus on improving the financial wellbeing of customers and equipping them to make the right financial decision, aligned to their goals and financial position. The key elements that comprise a trust architecture are:

  1. Transparency;
  2. Providing intrinsic value to the customer;
  3. Positive reinforcement through small data; and
  4. Focus on return on engagement.


Financial services firms can enhance their transparency by incorporating choice architecture principles and reducing sludges in their operations. As per Noble Laureate Richard Thaler, choice architecture refers to the way in which choices are presented to consumers which can greatly influence their decisions. By presenting information in a clear and easy-to-understand manner, financial services firms can help consumers make informed decisions about their financial products and services.

This can include simplifying the language in contracts and agreements, reducing fees and charges, and making it easier for consumers to compare different financial products. This, in turn, can help build trust and loyalty among consumers and ultimately lead to stronger, more sustainable banking relationships.

Intrinsic Value for Customers

Financial services firms can provide intrinsic value by shifting their focus to enhancing their customers’ financial wellbeing. By prioritising the financial health of their customers, firms can help consumers achieve their goals and build long-term wealth. Moreover, financial services firms can adopt a customer-centric approach that focuses on building relationships and providing value beyond just the transactional level.

Some key programmes financial services firms can run to encourage their financial wellbeing include:

  1. Financial literacy or financial coaching – Through personalised financial coaching to help customers set financial goals, create a budget, and develop a plan to achieve their goals.
  2. Financial wellbeing tools – Designed to help customers manage their finances more effectively, make informed decisions, and improve their overall financial health.

This can help customers with aspects of their financial life they may not have learnt about in school. It can also create value for customer groups like Gen Z, who are particularly vulnerable to the cost-of-living crisis and understand how they can plan better for the future.

By providing intrinsic value to their customers, financial services firms can differentiate themselves from competitors and build stronger, more loyal customer relationships.

Positive reinforcement of small data

Small data can be defined as: insignificant data insights from customers that can be gathered to give a fuller picture of their needs.

By leveraging small data, banks can offer personalised recommendations and advice that can help customers make better financial decisions. Banks can also use small data to identify opportunities to improve the customer experience. By analysing customer feedback and behaviour, banks can make targeted improvements to their services and products, such as streamlining the account opening process or offering more relevant and timely promotions.

Focus on return on engagement

Return on engagement is a crucial aspect of banking, as it measures the effectiveness of various customer engagement strategies such as fostering long-term relationships and driving profitability. With diverse customer needs across various life stages, it is essential for financial services firms to adopt tailored engagement strategies that cater to individual preferences and requirements.

By understanding and addressing the unique financial needs of customers at different life stages, financial services firms can build lasting relationships that enhance customer loyalty and satisfaction. Consequently, this long-term engagement not only bolsters the financial institution’s reputation but also increases the customer lifetime value, ultimately contributing to the financial services firms’ overall growth and success.

Developing customer trust is essential for financial services firms, especially during times of economic uncertainty. Financial services firms should recognise the Consumer Duty Principles as a key driver for innovation and transformation in the banking industry and leverage it to deepen their customer relationships and stay ahead of the competition. Financial wellbeing programmes form a crucial way for firms to build and maintain trust with their customers by providing them with valuable resources and information to help them manage their finances and achieve their goals.

Consumer Duty Principles present the perfect opportunity for financial services firms to make better progress toward customer centricity, resulting in enhanced business and consumer outcomes.

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Meet the experts

Chandramouli Venkatesan

Vice President – Portfolio Development Lead – Digital Front Office Transformations | Banking and Capital Markets
Chandra leads the Front Office transformation portfolio (marketing, sales and customer service) and serves banking and capital markets clients. He focuses his work on customer experience and helping financial institutions transform marketing, sales and customer service into more customer-centric organisations with an emphasis on experience strategy design, technology and data. Chandra has deep experience driving CX transformation for retail banks, payments companies, wealth management and capital markets firms.

Gareth Wilson

Executive Vice President – Head of UK Banking and Capital Markets 

Aalekh Bhatt

Go To Market lead – Digital Marketing for BCM @ Capgemini UK