How to use the Elevation Consumer Duty Alerts email

  1. Make sure the right people at your firm have access to the weekly email

We recommend asking your account manager to add your compliance team to the distribution list for the email.

  1. Develop a response plan for each type of risk. Here are examples:
Clients not confident they understand the potential disadvantages of their advisers' recommendations
Ensure the adviser is aware of the feedback, and the fact that it may represent a risk to Consumer Duty Outcomes 1 and 3.

Prompt the adviser to follow-up with the client to clarify the potential risks. Get an update from the adviser following this conversation.

Review the documentation associated with the adviser's recommendations.
Clients are not sure if they're on-track to achieve their goals
Ensure the adviser is aware of the feedback, and the fact that it may represent a risk to Consumer Duty Outcomes 2, 3 and 4.

Suggest the adviser undertakes the Elevation Passionate Advocacy Programme, which includes best practice guidance on this area.

Prompt the adviser to follow up with the client to discuss their goals, and whether they are on-track. Get an update from the adviser following this conversation.

Review the documentation associated with the adviser's recommendations.
Clients said they are not sure how their adviser's fees work
Ensure the adviser is aware of the feedback, and the fact that it may represent a risk to Consumer Duty Outcomes 2 and 3.

Prompt the adviser to follow-up with the client to explain their advice fees. Provide the below email template they can use.

Dear [client name]

Thank you so much for leaving feedback for me recently.

I saw that you answered "Not sure" to the question "How do you pay for your adviser's services?".

It is really important to me that all elements of the service I provide are as clear and transparent as possible, so I wanted to follow-up to clarify how our fees work.

Our fees are based on a percentage of the assets we look after for you. This year, that fee is 1% on assets currently valued at £224k.

Please let me know if I can clarify further.

Kind regards
[adviser name]
Clients don't receive any correspondence, find it unclear or barely read it
Where clients don't receive any correspondence:

Ensure the adviser is aware of the feedback, and the fact that it may represent a risk to Consumer Duty Outcome 3.

Check the correspondence addresses (including postal and email) on file for the client. Ensure correspondence has been sent to the most up to date address.

Check with the client to ensure their most up to date correspondence addresses are on file, and that they have received all correspondence you expect them to. If not, resend the correspondence.

Where clients find correspondence unclear:

Ensure the adviser is aware of the feedback, and the fact that it may represent a risk to Consumer Duty Outcome 3.

Check the correspondence they received from different sources, including emails from their adviser.

Reach out to the client directly to understand which correspondence wasn't clear.

Clarify and adjust correspondence if needed.

Where clients barely read correspondence:

Ensure the adviser is aware of the feedback, and the fact that it may represent a risk to Consumer Duty Outcome 3.

Ask the adviser to discuss this feedback with the client at their next meeting, to understand why the client doesn't read the correspondence, and explain the importance of the correspondence.
Client said they speak to their adviser less than once a year
Ensure the adviser is aware of the feedback, and the fact that it may represent a risk to Consumer Duty Outcome 3.

Check whether this client should receive a review meeting at least once a year.

Check records of meeting dates with this client, and understand any discrepancies with their feedback.

Ensure the client has the right frequency of meetings with their adviser going forward.

Review the most recent documentation associated with the adviser's recommendations for this client.
Clients would not ask a question until the next scheduled meeting
Ensure the adviser is aware of the feedback, and the fact that it may represent a risk to Consumer Duty Outcome 3.

Prompt the adviser to let the client know they are welcome to ask questions between scheduled meetings. Provide the below email template they can use.

Dear [client name]

Thank you so much for leaving feedback for me recently.

I saw that you answered "I would always wait for the next scheduled meeting" to the question "Between scheduled meetings, in what circumstances would you contact [adviser name]?".

I wanted to ensure you know that you are welcome to contact me with questions whenever they occur, and don't need to wait for a scheduled meeting.

Kind regards
[adviser name]
Clients only talk about finances with their adviser, or might feel uncomfortable talking about personal issues
Ensure the adviser is aware of the feedback, and the fact that it may represent a risk to Consumer Duty Outcome 3.

Also share this document with them, which explains why this response could be indicative of risk:

Between annual suitability assessments, the best way to discover whether something significant has changed in a client’s life, is often for the client to volunteer this information. If the client doesn’t feel comfortable doing this, there is a risk that circumstances change, advisers’ recommendations are no longer suitable, and this is not picked up.

The document also includes guidance for advisers on how to improve this area of their client service
  1. Each week when you receive the email, follow your response plan

  1. Record the risks flagged, the response and the outcome. Here is an example:

Date

Risk

Action taken

Outcome

17 April 2023

Client said they are not sure how their adviser's fees work

Emailed Adviser 1 to ensure they were aware of the feedback, and to provide the email template.

Adviser 1 sent the templated email, and followed up with a call with Client A, who is now clear on how our fees work.

17 April 2023

Clients don't receive any correspondence

Emailed Adviser 1 to ensure they were aware of the feedback.

Client B had moved house 6 months ago and not informed us.

We updated the address on file and resent all mail correspondence since they moved.

17 April 2023

Client said they speak to their adviser less than once a year

Emailed Adviser 2 to ensure they were aware of the feedback

Client C should have received a review meeting this year, but it was missed. There was no meeting scheduled.

Client C now has an annual review meeting scheduled.

Adviser 2 has received additional training on our policies around review meeting frequency.

A plan is now in place to improve monitoring and reporting of review meetings scheduled / held.

A full case check was carried out for this client with no additional issues found.


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