The FCA has published Discussion Paper 15/5: Smarter consumer communications (DP15/5).
The FCA expects all firms to embed an organisation-wide culture where the importance of communicating effectively with consumers is recognised and prioritised. The information needs of potential customers need to be fully considered when developing a product or service and throughout the lifecycle of that product or service.
DP15/5 is an interactive discussion paper and is intended to kick start a debate around how the FCA, industry, consumer groups and other stakeholders can work together to deliver information to consumers in smarter and more effective ways, including adopting innovative techniques.
In DP15/5 the FCA reiterates its expectations that firms:
- understand and recognise the importance of communicating effectively with consumers;
- create product and service information for consumers with at least as much behaviourally informed creativity as is applied to business development, marketing and financial promotions; and
- create communications as an integral part of the product or service design process.
The FCA notes that many firms are doing this and in DP15/5 it also signals its support and encouragement for firms that are:
- writing for the consumer first and then ensuring communications are compliant, rather than the other way around;
- moving away from a box-ticking approach to communication design, or the perception that communications driven by regulation are the responsibility of compliance and legal staff;
- building a wider understanding of their customers’ information needs and objectively considering not only what consumers actively demand to know, but also: (i) what the consumer needs to know; (ii) how much they need to know; and (iii) when they need to know it;
- prioritising efforts to ensure that information is effective for the intended audience and testing communications among real consumers; and
- adopting innovative techniques to improve how key information about products is conveyed and delivered to consumers.
Throughout DP15/5 the FCA has included specific examples of firms’ approaches to communicating with consumers. However, the FCA does not endorse or promote the circumstances provided by these firms nor has it assessed whether the communication, or the circumstances surrounding them, are consistent with its requirements. These examples do not represent a template that the FCA expects other firms to replicate, but it hopes that these inspire firms to think differently about how they communicate with consumers.
The deadline for comments on DP15/5 is 25 September 2015.
The FCA states that it will consider all comments and publish feedback on the responses received later this year. The FCA will also consult later in the year, on proposed changes to some of the Handbook disclosure provisions it discusses in DP15/5.
View DP15/5: Smarter consumer communications, 25 June 2015