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How does Amplifi address the Consumer Duty requirements?

Amplifi and the Consumer Duty

Updated over 11 months ago

The Amplifi assessment and simplification tool has been designed with the specific requirements needed to address the requirements set our in the Consumer Duty.

The functionality available enables clients to efficiently and objectively assess intelligibility and the likely consumer understanding outcome, and to target the simplification that might be required. This can help our clients to meet a number of their obligations under the Duty.

REGULATION OR GUIDANCE

HOW AMPLIFI CAN HELP

Regulation 2A.5.3 – to support retail customer understanding, firms must ensure their communications:

  • Meet the information needs of customers

  • Are likely to be understood

Amplifi is unique in the market, bringing together unique linguistic models and AI engines with classical readability metrics (e.g. Flesch-Kincaid).


This enables an objective assessment of how likely documents are to be understood by different demographics, not just how readable they are, and whether the reader is likely to be able to apply the information in practice.

Handbook Guidance 2A.5.7 – In supporting understanding through its communications, firms should:

  • Explain or present information in a logical manner

  • Use plan and intelligible language

  • Make key information prominent and easy to identify

  • Avoid unnecessary disclaimers

  • Present information at the relevant level of detail

Ensuring that firms’ communications with consumers use ‘plain and intelligible language’ and will be understood has been a challenge for firms for many years - particularly how to test this objectively, and at scale. Existing tools help to ensure good readability - for example that words and sentences are shorter. But many complex words and concepts often remain. Amplifi helps clients to identify the words and conceptual issues affecting how information is understood.

Regulation 2A.5.8 – in supporting customer understanding, firms should tailor communications, taking into account:

  • The characteristics of the customer base, including vulnerability

  • The complexity of the product

  • The communication channel used

Digital channels represent a great opportunity to augment and layer information, and provide additional support to assist customers’ understanding.

Even so, Amplifi is channel agnostic, able to assess communications in any written form – whether regulated documents, transcripts or web-based information, and from T&Cs to simple letters and text messages.

Regulation 2A.5.10 - For testing of communications, where appropriate, a firm must:

  • Test communications before communicating them to customers

  • Regularly monitor the impact of communications once they have been communicated.

Amplifi allows clients to test a huge volume of communications ahead of their delivery to consumers. It is quick and efficient and can be applied across a wide range of communications. It complements other assessments such as focus groups or randomised control trials that might also be used more sparingly, and can align to risk frameworks.

We provide clients with unique data, enabling targeted improvements where they are most needed, and a strong audit trail for reporting to senior leadership and the FCA.

Non-Handbook Guidance – Testing: Firms must:

  • Review products and services against all aspects of the Duty before the end of the implementation period, and on an ongoing basis

  • Tailor communications, taking into account the characteristics of the customers intended to receive the communications

Amplifi can enable firms to rapidly and objectively triage a wide range of customer communications to identify those where consumer understanding is at most risk, and thereby address those issues.

Regarding the need to tailor communications, the FCA has acknowledged that 1 in 7 adults have a reading age of 9-11 years, and a third have low levels of financial literacy. Amplifi enables firms to assess intelligibility against the capabilities of their consumers, enabling easier tailoring of information aimed at those specific cohorts, including vulnerable groups.

Non-Handbook Guidance 8.34 - Firms may consider their communications to be understandable, but that may only reflect the views of those involved in the design and sign-off of their communications – often legal, compliance and other financial services professionals.

Often experts and authors of legal or regulated documents struggle to write in plain language understandable to the average e consumer.

Amplifi provides clients with the means to identify and address this issue at source, via its assessment and simplification functions. It brings fresh eyes to any document review and content governance, and enables benchmarks to be set as part of your compliance process.

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