The FCA Consumer Duty: Your Product & Service Design Needs A Reboot

7 min read
Ben Logan
Service Design
Design Research

As the April 2023 deadline for assessing FCA Consumer Duty compliance for products and services looms ever closer, here’s a post with practical, hands-on advice for how to hit the deadlines and improve your performance.

What do customers want? What are their unmet needs, and the reasons why they behave the way they behave? If you want to land on the right side of the FCA regulations, you need a process to answer those questions and a roadmap going forwards. Here’s my Spotless FCA Consumer Duty checklist to help you get there:

Tip #1 – Research methods are everything – don’t skimp

There are no shortcuts or hacks to getting the qualitative insights you need to design really robust customer journeys that comply with the FCA Consumer Duty – so make sure you’ve mastered a core set of research techniques and methodologies you need to deploy at each stage. Like these:

  • In-depth interviews, design ethnography and diary studies.  Customer behaviour is not as predictable as we’d like it to be. Customers can fall off the happy path customer journey onto an unhappy path for a variety of simple reasons, like lost passwords, through to complex life changing events like unemployment or divorce. The only way to grasp the breadth of these issues is to talk to customers and stakeholders about the ways your products and services interact with their daily lives, observe customers at home and work, and ask them to keep diaries of their daily experiences and routines. This activity should help you recognise unmet customer needs and pain points, answering the question, ‘What does the person using this really need?’
  • Role playing and participatory design workshops. Get participants to role play interactions with your existing or proposed product or service, to give you insights into the way they react to your customer services and processes. Bringing them together with internal stakeholders for design sprints and workshops will also generate early stage ideas and aid in discovering internal issues that affect customer experiences and create friction. These workshops require expert facilitation from someone neutral, not a decision maker within the client organisation. You need objective, unbiased insights (not someone with skin in the game).
Two people analysing charts - UX Indonesia

#Tip 2 – build a robust programme for customer journeys (not products and services)

You need a plan to get from discovery (learning where products and services work – and where they don’t) through to delivery. A critical part of this work is recognising the customer may move around between products and services. For example, you might have a great credit card offering, but your personal loans team operates in a different organisational silo (for perfectly logical internal organisation reasons). Is it frictionless for a credit card customer to consolidate a card debt into a loan and move from one support team to another? Reducing that kind of friction is an example of why it helps to focus on the customer journey, not the product or service line.

  • Develop Personas, Mindsets and Antagonists Understanding your customers, their influencers and the forces that act against them, is a big part of the design challenge. Some of this will be discoverable from analysing customer support data and identifying customer segments with specific problems. However, the personas you devise from those scenarios are only part of the picture, because an ideal customer on the right product journey can suddenly find debts becoming unmanageable through a variety of factors – and what happens then?

One of the FCA’s major concerns is maintaining healthy consumer debt usage in the face of inflation, skyrocketing energy bills and rising mortgage rates. There’s a combination of unexpected and predictable economic pressures that could cause consumers to fall off the happy path, so you need to understand how the mindsets of consumers might change – even if their personas don’t. The same customer persona might change mindset from planning big purchases within their means, to careful budgeting to finance purchases at the limits of affordability, through to cutting costs to account for unexpected income loss – and you need to plan product journeys to match those changing needs. Are you making it easy or hard for them to pause or exit a service and signposting them the right way?

Additionally, the FCA is concerned about consumer trust and a great many trust issues arising from sophisticated scammers to sky-high APR credit offers, highly targeted buy-now-pay-later sales campaigns, gambling offers, even domestic abuse that occurs through financial controlling behaviours or online relationships. Planning journeys with these antagonist forces in mind must be a core part of avoiding harms for the customer – especially vulnerable ones.

  • Journey Mapping and Decision Mapping. A journey mapping exercise will usually take the lived experiences of customers and help your team define the typical customer journey through a product, and help you understand their goals and needs. However, journey mapping needs to be paired with decision mapping exercises, where the team considers the bigger picture for customers. Decision mapping recognises that customers exist within networks of other services and products, for example, if they have a credit card, a loan and a mortgage they have multiple paths to raise money for their life plans or unmet needs. Understanding what makes customers decide to use one instead of another, swap one for another, or choose competitor products is essential. Whilst we need to think in terms of journeys, we also need more of a systems thinking mindset for the bigger picture.

Tip#3 – remember there is a real world context for everything (co-creation)

Before developing a new product, you need to consider use-cases and explore them in a co-design process with customers and stakeholders. Which means…

  • Scenario planning (bulletproofing) & Co-Design What happens when things go wrong? Ill health, unemployment, divorce, moving house, being left with all the bills in a flat share, missed payments, children, a plumbing emergency, a sudden rise in the cost of a building project, a mortgage rate hike, an energy bill spike (etc.) Finding the answers to those questions is best served through a co-design activity, where you involve customers and stakeholders and work through some ‘how might we…’ scenarios with a working prototype of your products and services. This doesn’t need to be fancy, a mock-up using marker pens, A1 sheets, stickies and PPT software mock-ups can be highly effective.
  • Prototyping The key to successful prototyping is not to rush into high fidelity prototyping – like mocking up a mobile app using tools like Figma. Instead, ask yourself What is the quickest way we can check that this idea is on the right track? Lo-fi prototypes can be just as effective. You can prototype an interaction with a customer service representative using a script and participants, or mock up an advert or a brochure in PowerPoint. It’s the insight and outcome that’s important.Also, make sure you test assumptions around your channel mix with customers, especially ones in vulnerable circumstances. Some may prefer a phone call to a mobile app, or some may want to visit a branch – or different combinations depending on time and mobility. What you need to discover is, if someone has a problem, how your designs react and facilitate them to get the help they need or move from one product to another. The same designs might not work for every customer: changes might need to be made for specific audiences.
  • The end result of your prototyping activities should be a blueprint for a product where you have the right answers to the unexpected user behaviours and unmet needs that will otherwise make your products and services fall short of your FCA duties.

It’s not an impossible task to hit the short FCA schedule, but it’s never a bad idea to bring in more resources to make sure you do. If you want to know more about how we’re helping clients meet the FCA Consumer Duty deadlines, follow us on our socials or contact me via email here – and if you missed it, read parts 1 and 2 in this series to learn more about the FCA Consumer Duty and what it means for your brand…

MORE from us
View All
headshot of Ben, Director of Spotless
Got a project in mind?

Ben is on hand to answer your questions.