Consumer Duty compliance with verified reviews

The Financial Conduct Authority's (FCA) Consumer Duty came into force in the UK from 31 July 2023 for existing products and services with huge implications for the financial services sector. Since then, businesses have been required to tangibly demonstrate that they are compliant with the rules. 

The majority of reputable businesses were already meeting the requirements, but the challenge has been to document the evidence in a clear, measurable way. Firms are expected to monitor and review the outcomes their customers are receiving, identify poor outcomes, and take appropriate action to rectify the causes of the poor outcomes.  

While no precedent has yet been set for non-compliance, it is expected that the FCA will take action against businesses that fail to comply in due course. At the time of writing, what constitutes a serious breach, and the consequences, are to be determined, but demonstrating that you are proactively working to meet the requirements will help avoid any issues.  

Customer reviews are great for building trust, but they can serve as a vital compliance tool.

1. Products and Services
   Insights in customer feedback can help you understand their needs better and ensure your offerings deliver tangible value.
2. Price and Value
   Use customer comments to validate your pricing strategies and ensure customers feel they are receiving value for money.
3. Consumer Understanding
   Ensure clarity in communication by analysing customer feedback for potential misunderstandings and follow up.
4. Consumer Support
   Address the needs all customers, and ensure equitable treatment for customers who may be vulnerable by interrogating feedback.

85% of consumers trust online reviews as much as personal recommendations, so displaying feedback is essential for building trust. But the insights contained in customer feedback help you to improve your business and if done right, they can help you meet the requirements for Consumer Duty Outcomes.  

Your experts are already taking care of the Products and Services, and Price and Value requirements. Where we can help is with the Consumer Understanding, and Consumer Support pillars. These pillars are about knowing what your customers want and need, and how best to give them the support they want – which is what responsible businesses are already doing. 

Feefo features that support Consumer Duty compliance

Custom Feedback Questions

Use Custom Questions to tailor feedback forms to capture insights that matter:

• Identify vulnerabilities through targeted questions.
• Trigger additional queries based on low ratings to address concerns promptly.

Multi-Touchpoint Review Collection

Feedback Request Manager allows you to collect reviews across all customer interactions:

• Online and in-branch experiences.
• Post-purchase follow-ups to ensure ongoing satisfaction.
• Towards the end of a policy term to reduce the risk of churn.

Private Feedback Campaigns

Gather insights without publishing reviews publicly. This can be useful where a customer has closed an account or cancelled a policy. Use these insights to refine processes and mitigate risks.

AI Moderation and Reply Automation

Leverage Feefo's AI tools to help:

• Detect and remove inappropriate content with AI Moderation.
• Provide quick, consistent responses to customer feedback at scale with AI Replies.
• Flag concerns that may require manual attention.

Verified feedback means that reviews come from genuine customers who have experienced your products or services. Here’s why this matters for Consumer Duty compliance:

• You can identify recurring issues and take proactive measures to resolve them.

• Following up on feedback allows you to demonstrate accountability.

• Providing transparent and verifiable evidence to the FCA when necessary.

Open review platforms allow anonymous users to leave reviews, with no way that you can follow up. Businesses may also receive false feedback on these platforms, leading to data without integrity.

Reviews from open platforms can be a part of your customer support and trust strategy, but typically cannot be used to meet Consumer Duty requirements.

Here's a quick overview of the differences between verified review platforms and open feedback platforms.

Verified feedback (e.g. Feefo) 

Open feedback (e.g. Trustpilot) 

If you’re already using Trustpilot, Google reviews, or another feedback collection provider, you may have amassed a huge number of reviews, and understandably, you may be reluctant to abandon those. However, a few things to consider: 

• Potentially fake reviews may leave customers reluctant to trust and purchase; 36% of people don’t trust reviews on open platforms such as Trustpilot.

• False feedback from people who haven’t interacted with your business is data without integrity; it doesn’t help you improve your business and doesn’t provide an authentic picture of your business.

• You can’t follow up with anonymous reviews on open platforms, and so cannot be used to show compliance with Consumer Duty.

• Old reviews don’t provide an accurate picture of your business right now. Feedback from five years ago is irrelevant to today’s customers, and so old feedback becomes essentially worthless.

Keeping those existing reviews may be important to your business, especially when you’ve collected positive feedback. But because open platforms allow people to leave reviews anonymously, you can’t guarantee feedback has been left from genuine customers.  

Trustpilot have recently introduced verification steps via AI in the content publishing and verification workflow. This means if an anonymous customer makes a complaint about a business via Trustpilot, the business can’t contact the customer to follow up and resolve the complaint. Their AI tool may also mark a review as fake, which again, means you can’t follow up.  

This is a problem in terms of meeting the FCA Consumer Duty directive 1.3.3:  

A respondent must put in place appropriate management controls and take reasonable steps to ensure that in handling complaints it identifies and remedies any recurring or systemic problems, for example, by:  

1. analysing the causes of individual complaints so as to identify root causes common to types of complaint; 
2. considering whether such root causes may also affect other processes or products, including those not directly complained of; and 
3. correcting, where reasonable to do so, such root causes. 

To avoid losing ratings and reviews on Trustpilot, many businesses are choosing to work with both Feefo and Trustpilot. Examples of businesses that are using Feefo and Trustpilot concurrently include SecureTrust Bank, Atom Bank, LV=, and AXA.