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Consumer Duty – an opportunity to improve trust in the insurance sector

Read AMI Senior Policy Adviser Stacy Penn's latest article, published in Moneyfacts

Last year marked the Association of Mortgage Intermediaries’ (AMI) third Viewpoint on the UK protection market. The survey involved 3,000 UK adults and 254 IFAs/mortgage advisers and included qualitative research for the first time, by seeking views from a bespoke community of 16 adults. This added extra depth to the findings and brought colour to the statistics on the page.

It’s clear that mistrust is a common theme; from mistrust of insurer claims statistics (56% of consumers don’t trust them) to mistrust of advisers’ motivations (50% of consumers think advisers are motivated by commission). As one participant in the qualitative study commented: ‘I don’t believe that insurance brokers or financial advisers would offer an unbiased opinion; I think they would be swayed by commission or they would push people towards certain providers to get the most money out of it’.

The percentage of consumers that don’t trust their adviser’s motivations has hovered around the 40%-50% mark since the study began in 2020. Changing consumer opinion can seem insurmountable, particularly when negative consumer views on insurance at a societal level can transfer across into protection.

However, with the FCA’s Consumer Duty incoming it’s an ideal opportunity for mortgage advice firms to review whether they can make changes to their protection proposition and the consumer experience to improve trust.

Value of advice

Consumers may see little difference between receiving ‘information’ and ‘advice’. With Google part of our everyday vocabulary and even used as a verb (‘I’ll Google it’), it can be easy for consumers to feel they have access to ‘advice’ at their fingertips. However, type ‘life insurance’ into a search engine and you’ll receive over two billion results…not so easy to navigate, even if you think you know what you want.

If your firm hasn’t done so before, try writing down the benefits consumers receive when they come to you for insurance advice. Examples could include how your firm liaises with insurers on a customer’s behalf, how it explores customer’s needs and provides a personalised recommendation, has a team with x years of experience, or specialises in sourcing insurance for harder to place cases. This will be different for each firm based on its scope of service.

Articulating the benefits in this way may help firms re-consider how they explain to consumers what they do and the value they add. The Consumer Duty sharpens the focus on what firms must deliver, so firms should ensure they are realistic and transparent.

Firms are still required to issue customer communications stipulated under statute or regulation but the purpose of this exercise is to help firms think more broadly about their services and how this is communicated both internally as part of its culture and externally to consumers.


We know from AMI’s Viewpoint research that over half (56%) of consumers say they would go online if looking to purchase protection. A firm’s website is its digital shop front and Consumer Duty presents an opportunity to carry out a website ‘Spring clean’.

Consider how your firm can bring to life the role it plays in the insurance process via its website. There’s no harm in talking about insurance products but what’s likely to resonate more with potential customers is how your firm provides solutions.

If you’re able to provide real life testimonials or case studies of how your firm helped arrange insurance (with customer permission if personal information is used) this draws out both the human side and the important role of insurance and advice. This may help tackle the consumer narrative that firms only suggest protection to increase their earnings.

Consumer Duty also promotes better business practices by requiring firms to review all their communications (written, verbal and digital), with the FCA providing within its guidance helpful suggestions on ways to tweak areas such as language, layout and display to improve consumer understanding. This is a valuable piece of work for firms given that some of the participants in the 2022 Viewpoint qualitative study cited ‘overly complicated and wordy’ and ‘confusing and not easy to understand’ language as a barrier.

Consumer Duty is not about re-inventing the wheel; it’s about refining a firm’s proposition and practices to act to deliver good consumer outcomes and provides the chance for firms to tackle some of the consumer barriers we know exist in protection. If viewed as an opportunity instead of another piece of regulation, it will not only be consumers that reap the rewards but firms too.

Sources: The Great Protection Shift (2022), Protection: Moving Forward (2021) and The New Protection Challenge (2020).

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