Consumer Duty: Innovation Blocker or Driver?

In our latest Blog, GK Customer & Innovation Lead Shân Millie reports back on her key take-outs from our most recent webinar dedicated to this topic hosted by GreenKite on June 28 …

I’ll be honest: I’m obsessed with Customer and I know how important Consumer Duty will be operationally (and culturally), but nonetheless my heart did sink a little bit when I realised that of course our 2022 webinar series needed to include a session dedicated to this topic. Why? Because of the sheer volume of commentary, events, workshops, guidance notes and the rest that you’re being bombarded with now that the timeframe is set… There are some juicy (scary?) headlines out there: my favourite so far is “…a seismic shift for the sector that will impact up to 51,000 firms”. What’s yours?

Everyone has their own ‘take’ on the detail of impact, gaps and priorities, but commentators inside and outside the sector agree that this is a hugely-significant development for retail Delegated Authority firms – their partners, principals and capacity. And as Delegated Authority specialists, GreenKite is right in amongst it.

Consumer Duty

The Principle: statement of the standards of behaviour expected from firms.

“A firm must act to deliver good outcomes for retail clients”.

The Cross cutting Rules: development of the Consumer Principle across the various areas of firm conduct requiring firms to take reasonable steps to:

  • act in good faith
  • avoid foreseeable harm to customers
  • enable customers to pursue their financial objectives.


The Outcomes: A set of rules and guidance that will determine firms’ conduct in relation to:

  • communications
  • products and services
  • customer service
  • price and value.


We got together a compact but diverse and hugely knowledgeable panel: seasoned Compliance practitioner Claire Carpenter;  award-winning Claims and CX leader Vicki Heslop of Covéa Insurance, and Protection and Access expert Johnny Timpson OBE, formerly of Scottish Widows now running his own firm and Non-Exec Chair, of Absolute Military (amongst many other things). And me: a FinTech, Digitalisation and Governance ‘nerd’ leading for GK on Innovation and Customer, and coming at this from the viewpoint of individual leaders across the firm (and at Board). What’s the absolute need-to-know  — and act upon – for those building and growing firms that the technical experts like Claire, Vicki and Johnny want us to hear?

So much actionable and thought-provoking insight came out but here are three specific points that really stuck with me.




“We get the regulation we deserve”.

Johnny put it bluntly – and in their different ways, Claire and Vicki agreed. So whilst many continue to talk about ‘too much Regulation” (including some folks tuning in to the webinar), our experts’ view was clear: there should be no surprises here in recognising Consumer Duty not just as an opportunity to put Customer at the heart of the business (which it is) but as a REQUIREMENT in response to the view that currently, in our sector, this is patently NOT the case, and that Consumer Duty aims (in Claire’s words) “… to get to the ‘soggy bottom’ of the cupcake, to the core of what’s not working.”

“This is not a job for Compliance – it’s for the whole business.”

Unanimous agreement from the panellists that the biggest mistake for a firm would be to treat Consumer Duty as “… another set of tick-boxes” or even as a serious item but restricted essentially to Governance, Risk and Compliance. This is a challenge – from Johnny’s Absolute Military Board, to Claire’s clients in Digital Promotions and to the entire firm as Vicki described when she shared the Covéa response, essentially an enterprise-wide change project that (as she put it) is “growing arms and legs” – with some additional, tricky, dimensions for Commercial Lines business.

“Consumer Duty is ALL about driving Innovation, not blocking it!”

At the heart of the issue for our panellists is that fundamentally, the underlying products being sold, delivered, managed and experienced by the Customer are not fit-for-purpose, amongst the examples they shared:

  • the design of the benefit is out-of-date, like Term Life Insurance when what’s really needed is Income Protection and Support products that work for the 2020s
  • Terms & Conditions that effectively ‘switch off’ the intended product benefit design as in Claire’s examples of innovating MGAs coming up against insurers not “…jumping on board with Innovators (trying to improve the product)” .

“It isn’t clear, it isn’t simple, people don’t understand it, but it’s very, very valuable”

That’s NOT Consumer Duty – that’s Insurance. In 2022.

Time will tell whether the firm-wide and functionally comprehensive Innovation our panel think implementation of the Consumer Duty rules requires changes that. One thing is for sure: it’s going to be another challenging, fascinating, opportunity-rich 12 months for Delegated Authority firms and their partners working out what it means for them.

Shân M. Millie

Shân is GK’s expert in FinTech & Digitalisation and Innovation & Customer Lead.

Click here to listen in to the Consumer Duty: Innovation Blocker or Driver? Webinar on-demand

Click here for information on the GreenKite Digital Promotions HealthCheck specially-designed to help firms prepare for the new Consumer Duty rules


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