Let's Talk Income Protection

Consumer Duty is Changing How We Protect Clients Forever

• Income Protection Task Force • Season 2 • Episode 8

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Consumer Duty regulations are reshaping protection advice by shifting the industry from box-ticking compliance to a genuine focus on client outcomes. This shift enables advisers to deliver more meaningful, goal-oriented conversations about financial security.

Keith Richards from the Consumer Duty Alliance joins us to discuss how things are shaping up 2 years on, before we get an adviser's view from Jiten Varsani from FortyOne Money

Key learnings from this episode:

• Consumer Duty represents a transformation from prescriptive, rules-based regulation to outcomes-focused approaches
• Keith Richards explains how the Consumer Duty Alliance provides free self-assessment tools and resources for advisors
• Vulnerability considerations have expanded beyond permanent conditions to include temporary circumstances requiring additional support
• Claims handling is improving with streamlined processes, digital signatures, and dedicated support contacts
• Cross-referrals between protection specialists and wealth advisors are increasing to provide holistic financial planning
• Documentation now focuses on evidencing client outcomes rather than just product recommendations
• Consumer Duty encourages advisers to break complex advice into manageable, client-friendly segments
• The Protection Alliance is being developed to support protection specialists specifically

To claim your unstructured CPD and learn more about Consumer Duty, visit consumerduty.org for free tools and guidance. Register now for Income Protection Action Week 2025, running 22nd September, at iptf.co.uk.

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Produced and edited by SEA Studios

Speaker 1:

Hello and welcome to let's Talk Income Protection, season 2, episode 8. This is the podcast that breaks down everything you need to know about income protection, whether you're an experienced advisor or just starting out. We'll give you actionable insights, expert interviews and, of course, valuable unstructured CPD points. I'm Steve Yenoldi Content Associate for the IPTF, and I'm joined as always by the protection coach himself, matt Chapman. Matt, how are we doing in sunny, hot Spain? Hot and sunny.

Speaker 2:

Ay caramba and sunny ay caramba que bien que estamos disfrutando. No, you're totally right, um, honestly, I was just thinking a second ago. I can't believe. It's mid July, I know, and we're on episode 8 of season 2. Where has 2025 gone, mate?

Speaker 1:

it's gone in a heartbeat. Yeah, only two more episodes left of the season and, uh, yeah, it's absolutely flown by. But I've been enjoying every minute with you and we've got another fantastic episode this month work, how providers build products and how clients are supported. It has been two years since the FCA's consumer duty regulations first came into force. These rules aren't just another compliance hurdle. They do represent a real change in how the industry thinks about outcomes for clients. But before we get started, matt, what's your view on consumer duty and why it's good for the industry?

Speaker 2:

Absolutely, and it's interesting to note that I think consumer duty has probably been one of the main drivers behind my coaching business, because it led to a number of advisors and a number of firms asking the question around well, how can we be more compliant with consumer duty, how can we embed processes that lead to great customer outcomes?

Speaker 2:

And that's been instrumental in me then going around and helping support them, because fundamentally, this is stuff that I was doing in my original business. The advice model that we had, I always felt, was consumer duty compliant. We naturally placed income at the top of the tree in terms of priorities, because we recognize that in order to help any customer achieve any kind of goal, they need to make sure their cash point, that they've got the means by which they can borrow, that they can repay things, they can pay for their bills, all this other stuff. So for me, consumer duty was actually just kind of almost ratifying and validating what I was already doing, whereas I think for a lot of firms it initially felt like a bit of a knee jerk thing and they were maybe a little bit concerned about how it might impact their businesses. But I think time's shown us that actually it's a very positive thing for the industry, yeah completely agree, Matt.

Speaker 1:

And in this month's episode we've got two fantastic interviews. So first up, we're going to hear from Keith Richards, CEO of the Consumer Duty Alliance. He's in conversation with Vicky Churcher from the IPTF to talk about what's changed since the duty was introduced, how firms can embed it properly and how it relates to protection protection. And then, in the second half of the pod, I'll be speaking to advisor Jitin Vasani to hear how consumer duty is playing out in real world advice conversations, especially around income protection. So let's get into it.

Speaker 3:

Hi Keith. Thanks for joining us for the podcast. Lovely to have you with us.

Speaker 4:

Hi, vicky, it's great to be with you again.

Speaker 3:

And let's start with the basics. For anybody listening who doesn't know too much about Consumer Duty or Consumer Duty Alliance, can you tell us a little bit more about it?

Speaker 4:

Of course and it's great to be with you again, vicky the Consumer Duty Alliance is the very first dedicated professional membership body for the personal finance sector which incorporates mortgage protection as well. It's independent, not for profit and, very importantly, it's got no commercial output or activities, so, completely unconflicted. The board are all pro bono, so it's mainly practitioners from the sector and other subject matter experts that give their time up for free, and we are looking to develop a protection alliance. So again, we don't want to leave any practitioners out. Across the sector Not least, of course, vicky consumer duty really has started to join up a more holistic approach.

Speaker 4:

So even if you're a specialist in the wealth area, the message is now getting through that you need a more holistic approach under the duty and if you don't specialize in an area, then you do need to have an arrangement where you can pass your clients on or introduce them to specialists in those particular areas. And of course, it's becoming an interesting landscape, even with an aging demographic, where you've now got lifetime mortgages starting to be considered even by some of the advised clients under an IFA that that might not be an area where an IFA is particularly familiar. So we're starting to see a bit more. Join up between protection you know lending and wealth management.

Speaker 3:

That's fantastic news and I mean you've expanded hugely and really you know music to our ears to hear that there will be a protection alliance and I'm sure lots of people listening will be very pleased with that news. So we look forward to hearing more about that next year, keith. Indeed, yes, Since our conversation last year, keith, what are your observations with regard to how insurers and advisors are responding to consumer duty two years on, yeah, it's like all major reforms, vicky, it varies.

Speaker 4:

It varies across the sector. But let's start with the good news, because even the FCA are regularly giving examples of good practice where they're seeing the market really moving forward in evolving their services to align with outcomes-based regulation. And I think, just for the listeners, just to remind everyone, the reason that this is so significant is, regulation was introduced in the late 80s and we've had the best part of three and a half decades of prescriptive rules-based regulation. Now that's often meant that good firms have had to create checklists or tick box programs that haven't necessarily resulted in better outcomes for the client, for the customer, but we've had to comply, otherwise you're in breach. The major difference now is a shift to outcomes-based regulation means that you can throw the tick boxes away, you can unwind complexity if you believe that it improves outcomes in rules. And then the four areas of outcomes. I would suggest that every good firm passionately believes that they deliver against those outcomes and I think what we're now seeing is that there's positive evidence that most firms are focused. I think the good news from a regulatory perspective is the regulator is now seeing that instead of someone failing a regulatory process, even where a consumer has not been disadvantaged. That's the kind of regime that we've had in the past. Now the regulator is actively working with the market where it can see itself that actually firms are committed to trying to deliver the right outcomes, even if sometimes there could be improvements in the way that, for example, we communicate with clients or the way that we simplify our language.

Speaker 4:

Take financial advice you know I was on the board of advice firms when we moved from Well, actually, I was on the board of a firm when we moved from reasons why letters, which was a one-page document and some of your listeners might remember those as well to the need to go to more complexity through a suitability report that included more of the soft facts, not just the hard facts, but they then grew from probably starting their life as six pages to. I can remember signing off, thinking it was bonkers at the time, but we signed off on a 75-page suitability report. We're knowing full well that it would add no value, but our compliance were convincing us. That's what the regulator expected us to do, so we did it. We complied.

Speaker 4:

Crazy, but what we're now hearing from the regulator is we need to unwind all those things because the regulator accepts. The regulator didn't tell us to do those 75 pages, by the way. We came up with that ourselves and whether it's 75, 65, some of your listeners on here will, I'm sure you know, have their own towers of where they know that their clients don't read these reports. So they're really not delivering against improving client understanding, confidence and empowerment. But maybe unwinding to a two-page suitability report is exactly where we need to go.

Speaker 3:

And.

Speaker 4:

Outland's base regulation is going to allow us to do that, so it's going to take a bit of time. First of all, we've had the FCA do a couple of big events with the Alliance one in Scotland, one in Northern Ireland. We've got another one coming up in Newcastle where the regulator themselves actually participate in three key sessions on the delivery of examples of good practice, which has gone down exceptionally well with practitioners. They're not evading answering any question that comes from the audience, which is really refreshing. But actually they keep talking about proportionality for small firms. What they do recognize is small firms by definition. You usually find the principal has to do a bit of everything, so they're usually a lot more engaged in the end client experience, the outcomes based principle. I think we're now seeing a much, much different approach from the regulator who's now actively engaging. Uh, they're certainly a lot more visible across the market I agree.

Speaker 3:

I mean I was at the afm association of Mutuals Conference and the FCA were there, and also at the recent cover event. So, yes, visibility is good and not hiding behind what they're trying to achieve is really useful. So it demystifies what they're trying to do, which is great, and aids understanding for everybody. On the subject of vulnerability, keith, when someone claims on an income protection policy, by definition they're vulnerable because they've suffered or are suffering from an illness or an injury which means they can't work. Are you able to share any examples of what firms are doing well and, conversely, what they're not doing well to identify and support vulnerable customers and particularly interested? If you think AI could be something that could be used in this space?

Speaker 4:

Yeah, it's whenever there's a an increased focus on subjects like a client's circumstances. So the first thing I'd say to your listeners is vulnerability as a word, I think has confused the issue, because we tend to think about people. I mean, clearly, if they've got a claim, then it's an identifiable issue that they're facing and therefore that could give them a temporary period of vulnerability. We tend to move away from vulnerable circumstances to talk about client circumstances and that's where that creates a need for different support to bring in other colleagues. And to your point about AI we are seeing that firms are using intelligent technology, ai, where it can identify different stress levels and then create questions. So we're seeing that adopted across the market. It's about any client circumstance.

Speaker 4:

So the first thing an advisor will do is try to understand the client's objectives. Thing an advisor will do is try to understand the client's objectives. They might have to help the client understand that their needs actually should take a priority over their objectives. So they may want to do one thing, but an advisor will identify that actually there are other risks that they need to consider properly as a priority ahead of that. So we talk about the needs versus the wants.

Speaker 4:

But a really important third factor when advisors give advice, is they address vulnerability when they ask the question of are there any other circumstances that I need to be aware of which might influence the advice I'm going to give you or the products I ultimately recommend? So what we're now seeing is that increased focus naturally plays to the role of professional advisors, where we might not have thought of the client as vulnerable per se, but we were really keen on understanding the client's needs and then prioritizing those and providing the right level of support. What we've not necessarily been good at is identifying that we've addressed those vulnerabilities, but we didn't record it.

Speaker 3:

Yeah, really interesting, and one of the things that we identified in our recent seven claim stories project and we were looking at claims and how an advisor can help a claim is actually a realisation that many of our clients we engage with them on email digitally these days and many of them, if they're in a manual job or English is their second language they don't understand the emails or they don't work like that, and they don't understand some of the language being used or even how to use email. You know, please attach a PDF document or print this. They don't know how to print it or how to attach a PDF document. So you know, we need to really be mindful of who our customers really are and obviously that's the whole point of consumer duty.

Speaker 4:

So one of the things in vulnerable circumstances is technology can sometimes be a hinderer. It's not a great experience when you're having to kind of work out for yourself what you need to do. You just want to talk to someone that will take you straight to the support that you need. So I think we're seeing technology as an enabler for human beings rather than a replacement. I mean, there are some things clearly you can do, but I think it's making us think a little bit again about, you know, sometimes utilising technology that's enabled organisations, especially big organisations and insurers, to perhaps make 50 people redundant. Maybe that was the wrong outcome, because it's not a great experience just dealing with technology alone, unless that's what you want to do, and I think that's the change we're seeing is to your point, not everyone is as familiar using even email in the same way, Just moving on to the next question then, Keith, if we can.

Speaker 3:

As some of our viewers already know, the IPTF was created 20 years ago so we're 20 years old this year and it was created because income protection was under-advised and under-sold at that point. It's been a bit up and down since, but just recently we've seen some very encouraging growth. Do you think consumer duty has a role to play in that and has led to more proactive engagement from advisors and providers with this product?

Speaker 4:

I do Absolutely Vicky. I think there's a lot of conversation going around about the holistic financial planning side of things and, to be fair, also on the mortgage side. We've seen more active conversation about mortgage brokers not just being arrangers of a loan but actually the supplier of advice and, in particular, around protection products. In the financial advice world. There's a lot of conversation going on about being a bit more holistic. Again, here's one interesting statistic by the end of this year, 65% of the UK's wealth will be in the hands of women.

Speaker 3:

Yay, at last.

Speaker 4:

Yes, and actually it's not the intergenerational wealth transfer that's as big a threat as people have made out, but nonetheless, actually what it's forced a lot of firms to do is think about not a client but a family.

Speaker 4:

So they tend to think about you know how do you engage throughout the whole family? So we're seeing lots of advisors that are offering effectively a free consultation with adult children in particular. Those conversations are in themselves leading more often to a protection recommendation rather than, obviously, an investment, because they're more often in the place where they haven't accumulated assets at that stage. But they certainly need to protect and they've often got young families and income protection becomes absolutely a key consideration given the risks that we face in life. So I'm seeing a lot more financial advisors being drawn back into being a bit more holistic, but there are reasons for it. It's not just that they've switched on to it. They are thinking about the wider family of a client and how they engage the next generation to be the next generation's advisor as well. But if they're unengaged, there is that risk that I think statistically when wealth transfers is that they don't always use the same advisor.

Speaker 3:

No, but I mean that's good news and I myself have experienced that. Actually, my advisor has started my I've got three grown-up children, all one needing a mortgage, another just first job, pensions etc. And that advisor has engaged, has has taken on a younger advisor to to deal with the younger clients on on their level. So that's all been very interesting, keith. Thank you so much. Final question for you it's just been over two years now since consumer duty came into force, but if firms want to benchmark their own practices or find resources to support the work that they're doing in this area, where can they find this kind of information? Where should they go, apart from listening?

Speaker 4:

to our podcast and our video, of course go, apart from listening to our podcast on our video, of course, of course. Well, if they, if they visit uh, consumerdutyorg um. Wwwconsumerdutyorg um. We've got two self-analysis tools that that cover all aspects of consumer duty that will allow anyone. They're free to use um. They can also be used as part of an audit trail, so where the regulator is keen that firms understand, where they can evidence that they're doing the right thing. So it's no good just saying I know I'm doing the right thing. We've got to be able to evidence that.

Speaker 4:

There are two free analysis tools that any firm can access via our website which will help them benchmark. So there are benchmarking tools as well. In addition to that, there's free resources available on the sharing of good practice in various aspects of consumer duty. But we also signpost off to other organizations because there is a wealth of information out there but I guess a bit like consumers not knowing where to start. In fairness to advisors, it's sometimes as daunting for them as where they go. So we're trying to create a repository where it's not just about the resources we provide, it's signposting off to organisations like yours and others who can support and help them with that benchmarking.

Speaker 3:

Absolutely, and we're hosting in the advisor tools section of our website, which is the most popular visited part of our website. We are hosting some information about consumer duty, vulnerable customers, how to get in contact. So if anyone's listening, you can go through our own website too. Just click on advisor tools, top right hand side, and you can get through to the Consumer Duty Alliance information that way as well. Keith, thank you so much. That's been really useful. I'm glad, two years on, will I be speaking to you again next year, three years on, hopefully.

Speaker 4:

Well, consumer Duty is here for good. It's never going to go so. Unlike every other regulatory reform which you know things like polarisation, depolarisation, retail distribution, review they're regulatory terms. Consumer duty is what we've always been about, and even the regulator now realises that they've introduced something that is permanent. So, and I hope we never go back to rules based, prescriptive, rules based regulation. So I hope that I'm pretty confident, as long as we carry on on the path that we're going, that we're going to continue to see outcomes based regulation lead the way, which means the sector can own it, and on that basis, I think the consumer duties alliance consumer duty alliance is here for good. The Consumer Duty Alliance is here for good.

Speaker 3:

Excellent Good news and, on behalf of the protection industry, I'd like to thank you, tony and Emma, and the Consumer Duty Alliance for all your support for our industry, and we cannot wait to see what the protection alliance looks like, so we look forward to that one. Thanks ever so much, keith. See you again next year.

Speaker 4:

See you then, Vickyicky.

Speaker 1:

Thank you very much keith rich is the ceo of the consumer duty alliance. That's a fascinating discussion, wasn't it, matt?

Speaker 2:

absolutely. It goes back to everything I said when you asked the question at the beginning of the podcast around how we're going to move away from this kind of box ticking mentality to actually this is a chance to really get under the beginning of the podcast around how we're going to move away from this kind of box ticking mentality to actually this is a chance to really get under the skin of what matters to our customers, what their goals are, what they're hoping to achieve from the advice we're giving them, and then tailor our advice perfectly to achieve it, which for me just kind of like makes the whole thing that much clearer. And it's like Keith saying it at the end of the day, it's just about redefining how we perceive customers objectives, uh, how we redefine customers levels of vulnerability, how we give holistic advice the right way, and it just for me, it just all makes sense.

Speaker 1:

Just all makes its common sense. Yeah, it was a great uh interview with Keith and I also wanted to highlight that importance of their ongoing assessment with the CDA's free self-assessment tool that advisors and companies can go and check out. And also, you know, there's fantastic resources over on the Consumer Duty website too. And okay, let's move on. Let's chat to an advisor. Now. Let's chat to Jitin Vasani to get his view on Consumer Duty two years on, jitin is the founder but also an advisor at 41 Money Limited. Jitten, thank you so much for joining us on the podcast today. How are you doing?

Speaker 5:

Yeah, good Thanks, Stevie. Thanks for having me. How are you?

Speaker 1:

I'm very well. Thank you, yeah, pleasure to have you joining us for this consumer duty focused episode. Two years on now, Jitin, Is there anything that it did highlight or did it make you feel, okay, great, we're already doing these things. So you know, was that quite validating?

Speaker 5:

Yeah, to some extent, certainly from the protection side. I mean again, without sounding like I'm blowing my own trumpet I like to think we were ahead of the curve around putting the client first and making it a protection journey rather than just a protection sale, for example. But I think, if I'm going to sort of really look at the key areas we identified was so when I stepped away from investment pension advice, I did feel that maybe we weren't having as strong a conversation with clients around that part, even though I couldn't help them but signposting back to other advisors. So we talk quite a lot in our industry about the IFA community financial planners passing back to us from a protection avenue and I think we should also be looking to up our game about what we pass back, because those same protection clients will obviously have needs around investment, inheritance, pension planning and such. And if we're making it all about the customer journey, then by all means that was an area we, I think, identified to try and really improve our services etc.

Speaker 1:

Just not protection only, but as a whole financial planning journey okay, so it brought that client first approach to the rest of your products and services, so to speak.

Speaker 5:

then yeah, absolutely. I think sometimes it's quite easy to fall into the product first mentality, but focusing very much on the client's journey, what they're going to want to achieve between now, the next 5, 10, 15, 20, 30 years of their life, and then almost taking a step back to identify where are the gaps, what are the areas that they should be focusing on. But also we've really got to be mindful that when we talk about consumer understanding I've certainly been guilty of this in one meeting talking about protection, pensions, investments, inheritance tax you'd almost just overload them and then break it into smaller chunks, designing a bit of a, I guess, a plan of action that look immediately let's, let's cover your protection needs first and foremost, but put a plan that in the next three months we will talk to you about xyz and introduce you to the right people. That can complement the advice that we're putting into uh into play from today, and I think that's really had a positive impact on the client journey and the experience that our clients are having at the moment.

Speaker 1:

Yeah, certainly a theme that we've explored in previous episodes around. You know having more of a goals-led approach. You know talking to the client, figuring out what their needs are and then tailoring products and services to that. But moving on to claims handling and ongoing client support, have you seen any positive or unintended consequences of consumer duty? I mean for you and your business personally, but also the whole insurance landscape.

Speaker 5:

Yeah, I'm glad you mentioned the bit about both the industry as a whole and ourselves. I think, if I start with the industry as a whole, I feel from the claims personally we don't have a huge amount of claims so I'm probably not in the greatest position to answer this, but from what I have seen, stevie, yes, I feel that the conversations we're having with providers, there's definitely more focus on the claim side of the journey rather than just the let's get the client on board and I think that's phenomenal because, as we hear in our industry, you know the claim is the moment of truth, that when it pays out, how it pays out, et cetera, and improving that journey Because you know, sadly, we do an amazing job, I think, explaining protection, but at the time it's needed. If clients are waiting an hour or two on hold, we're not making that claims journey very user friendly old school paperwork that's got to be signed and manually posted. I'm hearing a lot of providers are really focusing on number one, bringing down the sort of contact approach, a one-point contact for clients, which I think is just amazing digital signatures, e-signatures, really adopting technology to improve that side of the journey. And I think, like I said, keep repeating the words moment of truth. What an amazing time to say well, we've managed to settle a claim in record time and I do believe there is more focus on there. Probably a bit more work to do, but at least the consumer duty has got that kind of focus in the right side.

Speaker 5:

From a personal side, I think what we started to realise was we have a duty of care, not just to the client but actually any of the beneficiaries, any of the trustees. So, using an example of a claim last year, it was a life cover policy that was close to £1.3 million. It was a life cover policy that was close to £1.3 million, a life and critical illness policy of close to about £130,000 there, and the client's estate already fell into a inheritance tax threshold. So simple things like just being able to explain to the trustees, the beneficiaries, that the fund's already in trust. You've just saved close to half a million pounds in inheritance tax, which, when that money is going to go to free young children again. I think it's that element of consumer support. What are we doing? Are we just handing over a check and just kind of moving away, but working with the insurance company? It was great because, even though the customer could have possibly claimed as the critical illness element of the KIC policy, they allowed the claim to go through as life cover, which in turn meant the money paid to the trust. That was another 30, 40,000 pounds in inheritance tax saved, which, when you're trying to raise three young children, that's going to be exceptionally phenomenal.

Speaker 5:

And I think, going around consumer duty, we have such a focus on our client, the people we set the protection up, for that there needs to probably be a little bit more work, training, and I've talked to a few providers around this, around the ongoing support for the beneficiaries and trustees, and one of the things we we did for this particular family was just introduce them to a independent financial advisor, and some of the things even I've learned is the trustees acts and registering the trust. And you and I, if we don't have much experience and most clients don't, how do you know what it means to be a good trustee? Are you ticking the right boxes to protect you and the beneficiaries? And so I think it's certainly consumer duty has made us think more about ongoing support, not just here's the claim, here's the money, thank you very much but helping people to ensure that the monies are used in the right and most efficient way and if, if it's beyond our scope, of course, bringing the right people in to assist with that part of the journey, really, but I think as a whole, as part of the consumer duty, looking at the protection advice process.

Speaker 5:

Is it we bolt it on at the end of a mortgage conversation that hey, by the way, let me just throw in a bit of life cover or are we actually making it a separate entity as part of our conversation with the client? And going back to 2013, the moment I did that, as in it became a separate conversation we suddenly saw the way our customers embraced protection as a important area, not just a bolt-on, and that really was a key change. And I think, as part of consumer duty, you've really got to look at how are you positioning it? Are you throwing it in? Are you, as an advisor, really highlighting how important it is? And by making it a separate conversation, I think that instills that confidence in the client that this isn't just about one. There is actually real value to this and build upon that side of things, which is a very useful thing. I found it made a massive difference to consumer understanding and how much of an uptake we saw in protection uh from our clients.

Speaker 1:

Yeah, just, and I've said it before on an episode I think it was the first episode of season two where my first uh experience of um insurance was, after, you know, sorting out the mortgage on the first home and then it was just like, right, okay, now you need your insurance. And I was like, hold on, wait a minute, what's this about? I had no understanding whether we even needed it, what it was for, and it just felt like I was being sold to. And you know, I've since learned by you know, listening to wonderful people like yourself and Matt Chapman every month how important it is for that to be part of the conversation up front. And that's exactly what I did when I got my income protection, where we talked about my goals and what I wanted to achieve. And you know how can we ring fence my income as as someone who's now self-employed, yeah to to achieve those, and that is 100 the right way to go about it.

Speaker 5:

So fantastic, stevie. The problem is I mean I've used this example before we treat it a bit like well, stevie, you bought a car. Do you want the mats to protect it? Let me just throw in a bit of after sale and I think as an industry we keep doing that.

Speaker 5:

You know, sadly, a couple of years, years ago, one of my clients rang me and he said is there anything you could do to help my sister-in-law? She's been diagnosed with cancer. And I said look, not really if after diagnosis, and certainly not just so soon after diagnosis and asked the question did she have any cover? And he asked her the same and she said well, no, I don't have a mortgage. And that to me, kind of hit home that actually we have such a misconception in our industry that you only need cover when you got a mortgage. Now, sadly, she passed away a couple of weeks ago. But the worst thing about this is now she's left her husband and her son with no cover, no financial security, purely because she didn't understand of why you would actually have the cover in place, because they were living with the in-laws at the time um, renting, I can't remember which one, but but either way, and and that's where the whole conversation needs to change, and signposting, highlighting so our website.

Speaker 5:

I created my own little video for my days of an IFA, which is don't talk about pensions, talk about retirement, don't talk about investment, isis, talk about freedom to travel, freedom to enjoy yourself and having the funds to do so, because those are just mere products. I mean, no one cares that. You know I've got a million pound at payout. The reality is, what will that money allow my beneficiaries to do when I'm not around? You know, do you care if it's called income protection or if it's called planning for armageddon? I mean, the product really means nothing. It's look, I've got a bit of financial security. That just means, if the worst has to happen, I can continue paying my bills, my food, my expenses you know if I'm able, I like to continue going traveling.

Speaker 5:

My kids don't suddenly have to stop all their after school kids school clubs. And that, I found, was how you resonate with clients, not by talking about products, but what it's there to protect. And and that again just came down to, how do you change the conversation away from what you experience, which is here's your mortgage Stevie, by the way. I just need to throw in a few products so I can say I've ticked my sales manuals and compliance, and I think that's the point. Stop. I think compliance would shoot me if I said this. But stop thinking with a compliance hat. Think of it as a human and then you know everything in compliance falls into place as long as you're doing the right job. That's what compliance is there to do right. Just make sure you're not going off piece and you are doing what's right by the client and work together with them.

Speaker 1:

So it's come full circle, jit, and you know, I think working with the IPTF has drilled in the importance of income protection. And let's say but you know, and you know anyone that starts speaking to me about insurance, I'm singing the hymn sheet, you know, I'm fully, I fully understand the value of it.

Speaker 5:

Well, the interesting thing I found was so I actually my first meeting with Clarence is it's a presentation on what protection is, and I use a lot of silly examples. I often say to people look, we all know what a brick is and what it does, but could you go and build and design a home? Probably not, and that's the thing. We all know what life insurance is. But could you design and actually create your own package of protection that's right for you and your family? And the answer normally is no.

Speaker 5:

But also the biggest thing was the misconceptions, because I'm sure a lot of your friends that you might talk to about protection it's a waste of money or never pay out. And I found that clients have these, whether they're vocal about it or whether it's a subconscious thing, and they might. And actually I found, amazingly, if you overcome them, an education on protection actually improves their understanding. And going back to the whole consumer understanding on part of the consumer duty side of things, it just helps. You know it does half the job for you because they know what they're buying into and therefore great as an advisor. We also got larger premiums. We also got more um uh, client engagement and and lapses. I mean what if I said I've had maybe four or five lapses in 13 years?

Speaker 5:

you know, it's it's making sure it stays on the book, which is obviously what we want as advisors, but more so that protection continues for the client. So, yeah, there's a lot of stuff I think needs to change, and slowly. What I do like is, without sounding too age, I do like that.

Speaker 1:

The new generation advisors I think I'm embracing that change a lot more, um, which I think is phenomenal really, and and hopefully these resources are there for for them so you've highlighted here, I think just well in my mind anyway, some of the challenges or pain points of embedding consumer duty companies may have, uh, in their day-to-day work yeah, I mean in terms of embedding consumer duty.

Speaker 5:

I think that's where some of the difficulties will lie. Um, how do you know you're not actually doing something right? And and I guess the only real way of doing that is measuring yourself against your colleagues, sharing experiences, examples of what's going on. Obviously, compliance is always going to be there as well to guide and assist, and I guess it's almost just looking back and stepping back and just looking at that overall customer journey with a blank slate. And you know we're all programmed to do things the way we've always done them and, uh, I don't know, maybe, maybe sometimes change is a little bit of a scary, daunting process.

Speaker 5:

But taking that step back and almost just evaluating and I think I've always looked at things that well if I was no longer around, how would I want that process to look like for my family, for my wife, and trying to help our clients through that similar journey of, well, this is the support she's going to need. Now, look, my wife's not very financially literate. She actually leaves all the numbers to me for some reason. But literally I think it's kind of how would someone in that position, who isn't actually financially confident, what support would she need, and that, to me, is something that, if we keep looking at ourselves as individuals not necessarily as advisors and our families and what they're going to require as part of that journey, I do hope that we can actually really nail consumer duty in the head around. What does the perfect journey look like, not just from the protection angle and the customer experience, but again from that whole wider financial planning perspective?

Speaker 1:

a financial planning perspective. Jitin, how do you identify and respond to clients in vulnerable circumstances? Now you know you mentioned about your wife and how she might deal with you know something happening to yourself. God forbid, we don't want that. Has your approach changed since the FCA's guidance at all?

Speaker 5:

Yeah, mean going back, I don't think we've changed much around the protection advice process, but certainly around identifying vulnerable customers. If you sort of look at the whole list of vulnerable customers, I think a lot of people would probably agree. There's certain definitions that we may not have originally thought that that would put someone into vulnerability, but it has done so. I guess from our perspective it was just really ensuring that, firstly, you don't kind of, um, we're not picking up and and really making a big deal out of the vulnerability, because we almost want every client to feel that they're going through that same, not to feel segregated in any way if that's the right way of wording it but at the same time making sure that they have more time. So sometimes we'll have additional meetings, break them into smaller sections, rather than again overloading too much information in one go, constantly asking questions around. Well, could you explain that back to me? Just making sure that they've understood it.

Speaker 5:

Involving, involving family members where applicable and I've often found certain customers do prefer that option of just having a friend sitting in the meeting or a brother, cousin, whoever, just giving them that support that we're working on their agenda. They can be as fast or as slow as they wish to go, and I think that actually, certainly from the vulnerability side and obviously more importantly, documenting the time was given. You know all the meetings, all the dates, who attended at each of those and, I guess, just literally working to the client's agenda so that you're giving them the support at such a time when they need it. To be honest, stevie, and I think again, that was something we definitely had to focus a little bit around identification and how you handle that scenario delicately.

Speaker 1:

Yeah, you're correct. I mean, yeah, you don't want to necessarily make special cases of people. You know everyone should be treated the same, but there are some you know level of extra care that may be needed for some clients. But I'm going to throw a bit of a curveball out here now, maybe playing a bit of devil's advocate. Jitin, do you think consumer duty has raised the standard of protection of advice or has it just added more paperwork?

Speaker 5:

I'm going to go with. It's raising the standard of advice and I think from a lot of the events we attend, a lot of the advisors we're talking to, there's certainly a lot more signposting. I think as an industry as a whole, there's certainly a lot of conversations, as we say, around protection, people understanding that we don't specialize in this area. So in the same way we may pass a client for conveyancing work to a specialist, to a will writer, someone who specializes in LPAs, conveyancing work to a specialist, to a will writer, someone who specializes in LPAs we need to start recognizing protection as a specialist area of advice, not something that someone can come in and dabble in. From my conversations with old colleagues in the IFA world and colleagues who run slightly larger firms to mine, who do have recommendations of referrals coming in, we're certainly seeing, I think, an uptake and a more of an interesting conversation around protection and signposting to the specialists. Again, is there an area where more work's required? Absolutely, and I'll go back to my previous point.

Speaker 5:

I do think that we as protection mortgage advisors also need to upskill ourselves to ensure that we're also passing clients back the other way, because these are important needs. I can give someone the best protection, but if they get to 65 and don't have any money to retire upon, then have we actually done what's right for the client as an overall advisory position? And so I do think it's a great thing to work two ways. I'm fortunate I work with a really good IFA. I'm always learning from him. He's always training me around things I need to be looking at. In the same way I'm explaining to him around what we want from protection. So, in simple summary, I think consumer duty is a great thing. Yes, I appreciate for some companies it's going to be a bit of an administrative burden, but if it means better outcomes at the end of it for the client, then how can that not be a good thing, stevie?

Speaker 1:

Jitten, thank you so much for your chat today. Is there anywhere that people should go to to follow you on socials or LinkedIn or anything like that?

Speaker 5:

Yeah, I'm on LinkedIn, on Twitter, actually a bit on Instagram. I'm trying to build up a little bit more of an online presence, but, yeah, you can find me on LinkedIn, twitter and certainly on Instagram and the company's 41.uk website. So should you wish to go and have a look at any of the stuff we're doing there, then by all means have a look and reach out if you feel like you need any help or assistance from me.

Speaker 1:

Jitten, thank you so much, pleasure to have you.

Speaker 5:

Likewise Thanks again.

Speaker 4:

Stevie.

Speaker 1:

Jitten Vasani. There, matt, we're approaching the back half of the podcast and you know what it's time for.

Speaker 2:

It's those actual takeaways and that conclusion that we all desperately need just to wrap this whole thing up, okie dokie Right over to me for the top tips and we'll break it down to those three levels, as we always do, from beginners to intermediate, all the way through to the more advanced advisors who feel confident having these types of conversations. So I've made absolutely loads of notes today, stevie, because there's just so much to take from both of those interviews. Now I would say that, probably for those advisors who are fairly new to the industry or even not quite sure how they can take the concept of consumer duty and apply it to their day-to-day advice conversations, here's some top tips for those beginners. First thing I'd say is shift from cover to goals. I've been saying it for time it's really important to understand the customer's objectives. So rather than asking things like, do you need life cover? Ask what would happen if you lost your income or your health suffered. Start from the client's reality and focus on what matters to them. The second thing I'd say is use simple language and human logic. Say we're here to help you achieve your goals, even when life doesn't go to plan, because that reframes essential as an essential part of their toolkit and helping them achieve their objectives, not something that's just optional or an expense that they don't need and then also recognize vulnerability in everyday life, whether that's first time buyers, those going through a divorce, those who are suffering from illness, those who are new parents All of these can trigger some level of vulnerability, as we heard from Keith. So learn to spot it and maybe use that chance to slow down your advice.

Speaker 2:

Now, moving on to the intermediate advisors I think this one the focus, has got to be on refining your processes and the quality of advice that you're issuing to your customers. Redesign your discovery meetings. So start by asking questions like what are your top financial priorities in the next five years? And then what you can do is align protection to those objectives, not just the mortgage itself. The other thing I'd say is document outcomes, not just products. So use the soft facts, not just hard data, to show why a solution was recommended. We heard from Keith talking about evidence being absolutely critical. So you know, use the client's goal as the main objective or the rationale behind your recommendation. Client's goal, for example, is to make sure the family can stay in the home even when they passed away unexpectedly. So then you can justify and explain that and link the advice you're giving and the products you're recommending back to the customer's objectives and goals and then break your advice down into bite-sized chunks. I think don't rush to close protection recommendations or sales. Instead, let's get protection sorted first, then we'll cover the pensions, then we'll cover the investments over the next few months, just like Jitam was saying, in terms of that holistic advice process you take with customers.

Speaker 2:

Now moving on to advanced advisors, those who've done the job for a while, those with a lot of confidence, a lot of experience, let me give you some great points on how you can amplify what you do and take your advice to the next level, especially when it comes to consumer duty. The idea here is about leading cultural change and embedding best practices. So coach your teams and your advisors to sell outcomes, not features. Train other advisors to focus on what protection enables and explain it to customers in that way. Ie, for example, keeping the kids in their school clubs, keeping food in the fridge, keeping lights on a roof over your head. Those tangible outcomes, audit and benchmark advice journeys. So use tools from the CDA, the Consumer Duty Alliance or your network to regularly check whether your advice evidences client outcomes in the way that it needs to. That way you can make sure on top of it and start to drive those best practices throughout your organization and your advice processes. And then finally, as Jitin was saying, champion those cross-referrals, create reciprocal relationships with IFAs, gi brokers, estate planners, will writers Refer up, refer down and refer sideways? Because consumer duty is about that holistic advice. It's about that whole person advice and making sure everything we do signposts exactly what the customer needs to achieve their goals and their objectives and the very reason they came to you in the first place. Okay, so those are the three levels and all the tips that I'm going to offer today.

Speaker 2:

So let's get into my main conclusion from today's episode. Well, this is what I want to do in terms of my wrap up. I just want to focus on this final thought from me. So the heart of consumer duty is this Firms must deliver good outcomes, including helping clients achieve their financial objectives. That's actually what it states in the regulation. So let's translate that for a minute and see what it actually means for us in the advanced community. Well, that means our job isn't to sell policies at all. It's to understand what the client really wants to achieve in life and then protect their ability to get there. For most people, their income is the engine behind every goal. So how can we not talk about income protection in every advice conversation? Whether it's home ownership, raising a family or even retiring early, income is always going to be part of that plan. So our advice must start there if we really want to make a difference.

Speaker 1:

Fantastic, matt. Thank you very much. Well, that is it for this month's let's Talk Income Protection. As always, remember to subscribe, rate and share the podcast it all helps. And remember to claim your unstructured CPD points. If you want more on this topic, check out the consumer duty alliance website for free tools and guidance, and follow the iptf on linkedin and instagram for more updates. And don't forget about income protection action week 2025 five webinars jam-packed full of incredible content across the week of the 22nd of september. Register now at iptfcouk, and that's all we've got time for. So thank you very much for joining us. We'll see you next month for another let's Talk Income Protection. Let's Talk Income Protection is produced by Sea Studios.