The act is a new consumer principle that requires firms to act to deliver good outcomes for retail customers and comes into effect in July 2023. Find out here how your SSP system can help you comply.
There are four main outcomes
Consumer understanding.
Price and value.
Products and services.
Consumer support.
And three cross-cutting rules
Act in good faith towards retail customers.
Avoid causing foreseeable harm to retail customers.
Enable and support retail customers to pursue their financial objectives.
How will my SSP system support my business to meet the act?
The Features and Benefits functionality within Pure Broking and Electra M3 can be used to compare products and ensure that the products quoted provide the cover that the customer requires.
The Marketplace quote results screen has been updated to display all the covers provided rather than by exception to ensure customer understanding of pre-purchase.
There is a requirement for it to be as easy for a customer to complain about or cancel a policy as it is to take it out, i.e. where customers can take out a policy online, they should be able to cancel via the same - the SSP 'Esuite’ solution already supports online cancellations.
Complaints can already be logged in your SSP system about a product or service, and these will be increasingly important as firms look to use this information to drive improvements and understand failure to meet desired outcomes.
Changes are being introduced in the latest versions of SR25 and SR26 within the complaints function in Pure Broking to allow complaints to be reported at the product level and to be exported (existing functionality in Electra M3). Refer to release notes for further details.
We are developing the cancellation function to support differential rates and fees within and outside the 14-day cooling-off period to ensure the customer receives the full and correct refund without any manual adjustments being required, timescales for this piece of work will be shared in due course.
Vulnerable customers should be identified and treated appropriately by all parties in the chain, whether this is a permanent vulnerability, such as being hard of hearing, or a temporary/short term vulnerability i.e. Following a bereavement or redundancy. This information can already be recorded against the client within our Pure Broking and Electra M3 systems.
The initial change being introduced by Pure Broking SR25 and SR26 and in Electra M3 (Genero only), is to allow brokers to record this information against the client against a codelist containing the FCA-defined categories of vulnerability (Health, Life Event, Resilience, Capability) and allow it to be exported into reports as required. Refer to release notes for further details.
There are also two longer-term activities being undertaken by SSP and more generally within the industry to ensure products and services meet the customer's needs:
IPID documents detail what a product does and does not cover; however, there is currently a lack of consistency in the handling of risk-specific special exclusions leading to potential mis-selling.
To this end, industry-wide analysis is being coordinated by Polaris to create a common definition of 'standard cover' for each main policy type. Once this analysis is complete, then Insurers, Software providers and Price Comparison Websites will work together to design a solution for any exclusions to be prominently flagged to ensure the customer knows what they are covered for pre-purchase.
There is an industry wide proposal that information related to any identified vulnerabilities should be shared between brokers and insurers to ensure the best outcome for vulnerable customers. We will be liaising with both our user group members and insurer partners to ensure any agreed solution suits both parties.
Who have we been talking to?
The Electronic Trading Practices Group (ETPG) chaired by Polaris is attended by member Software Houses, Insurance Companies, BIBA and Price Comparison Websites.
