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PRIN 2A.6 Consumer Duty: retail customer outcome on consumer support

Application

PRIN 2A.6.1R
  1. (1)

    1Other than in PRIN 2A.6.6R, this section applies:

    1. (a)

      to all firms to whom Principle 12 and PRIN 2A apply,2 who are responsible for interacting directly with, and providing support to, retail customers, such as through its customer services functions and including where the firm outsources its interactions with retail customers to a third party (in whole or part);

    2. (b)

      regardless of the channel used or intended to be used when interacting with, or providing support to, retail customers, including via electronic communications such as on social media; and

    3. (c)

      to all support provided by a firm to retail customers, such as in the course of or in connection with the firm providing customer services, including:

      1. (i)

        before, during, and after any sale of a product; and

      2. (ii)

        support that does not relate to a specific product.

  2. (2)

    PRIN 2A.6.6R applies to all firms to whom2 Principle 12 and PRIN 2A apply2.

Design and delivery of customer support

PRIN 2A.6.2R

1A firm must design and deliver support to retail customers such that it:

  1. (1)

    meets the needs of retail customers, including those with characteristics of vulnerability;

  2. (2)

    ensures that retail customers can use their product as reasonably anticipated;

  3. (3)

    ensures that it includes appropriate friction in its customer journeys to mitigate the risk of harm and give retail customers sufficient opportunity to understand and assess their options, including any risks; and

  4. (4)

    ensures that retail customers do not face unreasonable barriers (including unreasonable additional costs) during the lifecycle of a product, such as when they want to:

    1. (a)

      make general enquiries or requests to the firm;

    2. (b)

      amend or switch the product;

    3. (c)

      transfer to a new product provider;

    4. (d)

      access a benefit which the product is intended to provide;

    5. (e)

      submit a claim;

    6. (f)

      make a complaint; or

    7. (g)

      cancel a contract, agreement or arrangement or otherwise terminate their relationship with the firm.

PRIN 2A.6.3G

1For the purposes of PRIN 2A.6.2R(4):

  1. (1)

    unreasonable barriers are those which are likely to cause retail customers to take unreasonable additional steps to progress their objectives, including:

    1. (a)

      steps which are:

      1. (i)

        unreasonably onerous or time consuming;

      2. (ii)

        complex for a retail customer to carry out; or

      3. (iii)

        difficult for a retail customer to understand; and

    2. (b)

      asking retail customers for unnecessary information or evidence;

  2. (2)

    where a firm has included appropriate friction in its customer journeys to comply with PRIN 2A.6.2R(3), this would not amount to an unreasonable barrier; and

  3. (3)

    unreasonable additional costs includes where retail customers incur unreasonable exit fees or other charges, delays, distress or inconvenience.

PRIN 2A.6.4G

1A firm would be unlikely to meet its obligations in PRIN 2A.6.2R if its support to retail customers causes or would be likely to cause:

  1. (1)

    prospective retail customers to be prioritised over existing retail customers;

  2. (2)

    unreasonable delays when retail customers attempt to engage with the firm, including disproportionately longer call waiting times to cancel or make changes to an existing product than to purchase a new product; or

  3. (3)

    unreasonable delays to:

    1. (a)

      any payments due to retail customers after they have been agreed;

    2. (b)

      the firm requesting necessary information or evidence from retail customers; or

    3. (c)

      the firm processing information or evidence received from retail customers.

Dealing with representatives

PRIN 2A.6.5R
  1. (1)

    1Where a person is authorised by a retail customer or by law to assist in the conduct of the retail customer’s affairs (such as a power of attorney), the firm must provide the same level of support to that person that they would have provided to the retail customer.

  2. (2)

    PRIN 2A.6.5R(1) does not apply where the person assisting in the conduct of the retail customer’s affairs is also a firm.

Dealing with requests from other firms

PRIN 2A.6.6R

1A firm must deal with reasonable requests from another firm in an effective way and in good time to enable the other firm to support retail customers.