Consumer Duty
What is Consumer Duty?
The Consumer Duty comprises three related elements:
2. Cross-cutting Rules
- to act in good faith;
- to avoid foreseeable harm to customers; and
- to enable customers to pursue their financial objectives
3. Four Consumer Outcomes
A set of rules and guidance that will determine firms’ conduct in relation to
- Products and services: are designed to meet the needs, characteristics and objectives of a specified target market
- Price and value: Products and services provide fair value with a reasonable relationship between the price consumers pay and the benefit they receive
- Consumer understanding: Firms communicate in way that supports consumer understanding and equips consumers to make effective, timely and properly informed decisions
- Consumer support: Firms provide support that meets consumers’ needs throughout the life of the product or service
The Consumer Duty is a significant shift in the FCA’s expectations of firms. It introduces a more outcomes-focused approach to consumer protection and sets higher expectations for the standard of care that firms give customers.
Our Approach
Jupiter has always recognised the importance of putting clients first, as demonstrated by the firm’s cultural pillars. As such Jupiter are ensuring that there is a thorough understanding of Consumer Duty and its outcomes. We are making sure that all staff are aware of the need to act in a way that demonstrates an understanding, and adherence to, the new Consumer Principle and Cross Cutting rules by providing awareness and training on our broader Conduct Risk Framework including Consumer Duty.
Through the Consumer Duty Implementation, Jupiter has enhanced its existing robust Governance Framework to ensure that there is effective oversite of Consumer Duty by the relevant Boards and Committees. These boards and committees will have responsibility for reviewing and challenging Consumer Duty metrics, which have been designed to demonstrate that Jupiter is providing good outcomes for retail clients as well as ensuring there are processes in place to support its vulnerable clients.
Consumer Duty Champions have been appointed on both the Jupiter Unit Trust Management Board Limited (JUTM), Jupiter Asset Management Limited (JAM) and Jupiter Investment Management (JIML)Boards.
Consumer Support & Understanding
We are looking at all the methods we use to communicate with our clients and the ones they have available to communicate with us. Our review is taking the four outcomes into consideration to ensure that we continue to provide the best client experience.
- We are completing a full review of the letters that we send clients, to ensure that they are easy to understand and contain all of the information that we need to provide in a clear way
- We are looking at all of our literature to ensure that it is clear and easy to use
- We are looking at our processes and procedures to make sure that they are straightforward and provide the best client outcomes
- We are reviewing our online “My Account” function to ensure that it is accessible and meets our clients’ needs in a simple and straightforward way
- We are working closely with our administrators, SS&C, to ensure that we provide our clients with the help and information they need, when they need it, in the way that best suits them.
All of our client facing collateral is put through a rigorous approval process to ensure it is clear, fair and not misleading. Our investment marketing team have been trained on the updated consumer duty requirements and current collateral has been reviewed to ensure that it is easy to understand.
We have engaged with Research in Finance, an independent market research specialist, to gather client feedback on the quality of the communications we produce. After the feedback has been gathered and assessed, we then look to implement any changes across our collateral to ensure that they remain retail-friendly.
We have also created an online feedback form on our retail website to monitor our clients’ satisfaction when using the website. Clients’ feedback left in the online form is frequently reviewed and any feedback implemented. There are also regular meetings between our Marketing and TA oversight teams to look into clients’ inquiries and determine how to address their needs – from enhancing functionality on the website, to improving online user experience.
We are working on an initiative to proactively trace dormant assets and repatriate them with the beneficial owner.
Vulnerability
Over the past few years, we have completed a comprehensive review of our processes and procedures, using the FCA’s four key drivers of poor health, negative life event, low financial resilience and low capability, to ensure that we have considered how our clients may need different or additional information or support. Changes have been made however this is an ongoing, evolving process with updates being made regularly to our processes, how we communicate with you and how you can communicate with us. We are always looking at ways that we can improve the customer journey and provide the appropriate support to our clients to ensure that they achieve the best outcome.
Key Information for Distributors
Our EMT has been updated to version 4.1, which contains 10 new fields relating to Consumer Duty. As well as being available on our website, it has been distributed to our standard recipient list. If you would like to be added to the mailing list please contact [email protected] who will arrange this.
In addition to the information provided within the EMT, we have created a supplementary report to address the Consumer Duty outcomes not covered within the EMT, namely Product & Services, Consumer Support and Consumer Understanding, to provide distributors with the information they require to discharge their obligation under the duty. The report can be accessed below.
Annual assessment of value
Market and exchange rate movements can cause the value of an investment to fall as well as rise, and you may get back less than originally invested.