The Consumer Duty requires us to focus on consumer outcomes, putting the customer’s interests at the heart of our activities

CRK Motor Insurance Services and the Consumer Duty Principle

‍There are three key elements of the Consumer Duty, which are:

Consumer Principle 

‘a firm must act to deliver good outcomes for retail clients’, which reflects the overall standards of behaviour the FCA wants from firms, and which is developed by the other elements of the Consumer Duty.

Cross-cutting rules

Which develop overarching expectations that apply across all areas of firm conduct:

  • Act in good faith towards retail customers.
  •  Avoid foreseeable harm to retail customers.
  • Enable and support retail customers to pursue their financial objectives.
Four outcomes

Which give more detailed expectations for the key elements of the firm-consumer relationship, covering:

  • Communication: communications equip consumers to make effective, timely and properly informed decisions about financial product sand services.
  • Products and Services: products and services are specifically designed to meet the needs of consumers, and sold to those whose needs they meet.
  • Customer Service: customer service meets the needs of consumers, enabling them to realise the benefits of products and services and act in their interests without undue hindrance.
  • Price and Value: the price of products and services represents fair value for consumers

Monitoring

A key element of the Consumer Duty is the requirement for us to assess,test, understand and evidence the outcomes the customers are receiving.

We therefore:

  • Monitor and regularly review the outcomes that our customers are experiencing
  • Ensure that the products and services provided are delivering the outcomes that our customers expect in line with the Consumer Duty, and
  • Identify where they are leading to poor outcomes or harm to consumers.
Management Information

We will use data to measure our performance to ensure that we meet the requirements and examples of this are:

  • Management meeting minutes
  • Analysis of customer retention, claims, cancellation rates
  • Auditing of the customer journey, customer interactions and drop off rates
  • Distribution of product lines, communications, distribution channel review
  • Fees and charges applied
  • Process and policy effectiveness review
  • Complaints – trends/route cause analysis
  • Analysis of staff training records, CPD records
  • Staff sales observations/call monitoring/mystery shopping/auditing customer files
  • Staff feedback
  • Feedback Customer & third parties such as manufacturers inc. informal e.g. Social Media
  • Results of regular testing and monitoring, Compliance reports
  • External sources of data such as surveys

Where issues are identified, they will be addressed appropriately.Potential interventions could include:

  • Discontinuing a product or service,
  • Adapting product design/fees/charges,
  • Operation or distribution channels, or,
  • Redress where customers have suffered harm.

The Consumer Duty applies across all of our activities – from high-level strategic planning to individual customer interactions. Internal processes will be reviewed and customer service processes may need to be re-evaluated.

We will conduct regular Gap Analyses to ensure that we maintain required standards

We will be proactive in ensuring that our products and services are fit for purpose and provide fair value.

As part of the Consumer Duty we have produced a Product Oversight and Governance Policy document and individual Fair Value Assessments in respect of more specific Product Groupings which can be found here.

Product Oversight & Governance Policy

Individual Product Fair Value Assessments

CRK Motor FVA for Engineering products V2

CRK Motor FVA for Property Owners V2

CRK Motor FVA for Professional Indemnity V2

CRK Motor FVA for Private Car V2

CRK Motor FVA for Motor Fleet V2

CRK Motor FVA for Marine and Goods In Transit V2

CRK Motor FVA for Management Liability V2

CRK Motor FVA for Legal Expenses V2

CRK Motor FVA for Household V2CRK Motor FVA for Excess Liability V2

CRK Motor FVA for Cyber Liability V2

CRK Motor FVA for Contractors Combined and Contractors All Risks V2

CRK Motor FVA for Commercial Liability V2

CRK Motor FVA for Commercial Combined V2