CCR2 Compliance


Are we nearly there yet?


The path to online methods of customer engagement must be trodden with care, to avoid leaving some customers behind


Shada Nasrullah Compliance manager, the Lending Standards Board shadanasrullah@lstdb.org.uk


The revolution is underway; well, the digital one is at least. From a slow start, as firms gradually


developed their online platforms, now almost every organisation, we engage with, has embarked on a digital journey with the aim of improving and enhancing the customer experience. In fact, in the case of some challenger


banks, the entire customer proposition and associated functionalities are purely digital. And the pace is rapid. The big challenge


for regulators and standard-setting bodies is: how do we keep up? Moreover, how do we ‘acclimatise’ in this developing world to ensure that we deliver regulation, standards, and good practice that apply sensibly through whichever channel the consumer transacts? In designing the new Standards of Lending


Practice, this was high on our agenda – self- regulation must remain flexible enough to be applied for all customers, whether they are on a digital journey or a traditional banking one. One area that we know causes a lot of


discussion and debate, is in respect of vulnerable customers and the financially excluded, especially in ensuring they do not also become digitally excluded. We should be careful, here, not to stereotype; digital exclusion can apply to any part of the client base and ensuring the enhancements developed benefit everyone is essential if we are to achieve good consumer outcomes.


Vulnerability Our research, so far, has identified that digital developments can increase transparency and let customers track their finances, which can enable better financial decisions and help avoid fees and charges.


26 www.CCRMagazine.co.uk


Ironically, while this whole subject has provided so many pockets of great innovation, some of the more routine digital customer journey still feels fixed, with little opportunity for customers to deviate from the pre-determined ‘frictionless’ route, if they want to flag their specific needs or circumstances


An added benefit of what could be


described as ‘convenience banking’ is on the customers’ own health and wellbeing, decreasing anxiety and, at the same time, making it a powerful tool to help support vulnerable customers. However, we know that simply making


these various technologies available is not enough; banks need to do more. A key part of ensuring financial and


digital inclusion is being able to identify those customers who may benefit the most, and, once identified, encouraging them to use the technologies available. This seems to be one of the hardest parts of the puzzle to crack. We have seen some good innovations,


such as dedicated technology spaces in branches to help customers get to grips with new functionalities, with support on hand as needed, but more needs to be done.


Developments As part of our latest research project, we identified exciting innovations that can help make life easier for certain customer segments. For example, some organisations offer customers the ability to access their account using voice recognition or via fingerprint identification, which make remembering passwords a thing of the past; for visually-impaired customers, software can convert website text to speech. Ironically, while this whole subject has


provided so many pockets of great innovation, some of the more routine digital customer journey still feels fixed, with little opportunity for customers to deviate from the pre-determined ‘frictionless’ route, if they want to flag their specific needs or circumstances.


June 2017


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