Consumer Duty

The new Consumer Duty represents a change in regulatory expectations and requires us to go beyond the current Principles and Rules in putting our members at the heart of our business and culture and delivering good outcomes for our members.

The three components of the new Consumer Duty are set out below:

 1.  A new over-arching Consumer Principle

  • We must act to deliver good outcomes for our members

 

2. Three cross-cutting rules

We must take all reasonable steps to:

  • avoid foreseeable harm to our members
  • enable our members to pursue their financial objectives
  • act in good faith towards our members.

 

3. Four outcomes, representing the following elements of the firm/consumer relationship

  • Communications
  • Product design
  • Customer service
  • Price and value

 

The Society’s aims are set out below:

  • Being open, honest and transparent
  • Avoiding causing foreseeable harm
  • Giving fair value
  • Empowering members to access, understand and use products
  • Creating environments for good decision making
  • Helping members realise their financial objectives

Consumer Duty Implementation Timetable

By 31 October 2022 – Firms to have agreed their Implementation Plan

 

By 30 April 2023 – Firms should have completed their reviews of existing open products, and shared key information with their intermediaries.

 

By 31 July 2023 – Firms are to comply with the Duty in respect of new and existing products and services that are open to sale or renewal.

 

By 31 July 2024 – firms are to comply with the Duty in respect of all closed products.

Delivering on our aims:

The Society’s membership team can be contacted direct via phone or email.  All our calls are recorded for security and training purposes so that we can improve our service and protect our callers.

The Society handles all calls and emails in the same way – whether they are from a prospective new member interested in a new product, an existing member to provide a service on an existing plan or to close their plan.

The Society also places no barriers in delivering its services.  New members are provided with a reasonable time period to cancel their plan if they change their mind and existing members can close their existing plan, without any unnecessary barriers.

If a member is in vulnerable circumstances or facing financial difficulties, they can contact us and if possible and in the interests of the Society’s wider membership, we would be prepared to consider making other arrangements.

As part of our obligation to deliver on the Consumer Duty requirements, we have put together the following Target Market and Fair Value Assessment documents for all our products.