Consumer Duty

As a responsible, regulated lender we put consumers at the heart of our business and are committed to delivering good outcomes for our members, and potential members. As part of meeting the Consumer Duty, we:

• provide products and services that are designed to meet customers’ needs, that we know provide fair value, that help customers achieve their financial objectives, and which do not cause them harm
• do not seek to exploit customers’ behavioural biases, lack of knowledge or characteristics of vulnerability
  support customers in realising the benefits of the products and services they hold and acting in their interests without unreasonable barriers
• consistently consider the needs of our customers, and how they behave, at every stage of the product lifecycle
  monitor and regularly review the outcomes that our customers are experiencing and take action to address any risks to good customer outcomes
• ensure that our Board takes full responsibility for ensuring that the Duty is properly embedded within the business.

As distributors of our mortgage products, our intermediaries will also need to meet the Consumer Duty, including (but not limited to) the following:

• Distributors must have distribution arrangements for each product or service they distribute which avoid causing harm and mitigate foreseeable harm to customers, and ensure the needs, characteristics and objectives of the target market are taken into account.
• Distributors must understand the products or services they distribute which includes the product’s characteristics, identified target market (including those with characteristics of vulnerability), and intended distribution strategy.
• Distributors must ensure their own charges for distributing the product represent fair value to enable them to understand whether their distribution arrangements (including any remuneration it or another person in the distribution chain receives) would result in the product or service ceasing to provide fair value to retail customers.
• Distributors must, upon request, provide us with relevant information, including, where appropriate, sales information, information on cancellations, and information on the regular reviews of their distribution arrangements.
• Distributors must consider the needs, characteristics, and objectives of any customers with characteristics of vulnerability, and take account of behavioural biases and the impact characteristics of vulnerability can have on consumer needs and decisions. Any target market is likely to contain customers with characteristics of vulnerability and customers who will experience vulnerability over time.

For more information on the Consumer Duty, please visit www.fca.org.uk/firms/consumer-duty

For more information on supporting consumers with characteristics of vulnerability, please visit www.fca.org.uk/publications/finalised-guidance/guidance-firms-fair-treatment-vulnerable-customers