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Consumer Duty

As a packager we believe strongly in helping Brokers as much as we possibly can.  As such, we have the mind set to implement the same rules and regulations.

Since September 2022 we have been actively working through the Consumer Duty requirements so not only are we abiding by the new principle but also to assure Brokers that by using us as their packager they are also meeting certain outcomes proposed under the Duty.  But we haven’t stopped there, we have produced evidence to support our work which Brokers can also use as part of evidencing and embedding the Consumer Duty into its daily practice.


All products and services that are sold or renewed from the 31st of July 2023 fall under the Consumer Duty, of which there are three key elements as follows:

Consumer Principle

This is a new Principle, (Principle 12) which states that ‘A firm must act to deliver good outcomes for retail clients’.  This Principle sets the tone and reflects the standard of behaviour the Regulator wants from firms.

Cross-cutting Rules

The cross-cutting rules articulate the three key behaviours that the Regulator expects firms to deliver across all areas of the firm’s conduct:

  1. Avoid causing foreseeable harm to customers
  1. Enable and support customers;
  1. Act in good faith.

Four Outcomes

The four outcomes provide the rules and guidance setting more detailed expectations for firm’s conduct covering:

Consumer Understanding

This outcome requires that communications are easy to understand, provide a balanced picture of the product, including the benefits, cost and risks.  This includes providing the customer with everything they need in a timely way so that they can make an informed decision whether to proceed.

Products and Services

The products and services a firm offers should meet the needs, characteristics, and objectives of the customers that they are targeted at.

Price and Value

Products and services should be a fair price.  But it’s not all about price, firms are also required to assess the value of the policy and the benefits it provides.

Consumer Support

Consumers should receive support throughout the life of a product or service provided.  This includes making it just as easy for a customer to get in touch to cancel or change a policy as it is to purchase, through the same channel.


3mc had the pleasure of sitting down with Suzanne Gibson from Ecompli to discuss Consumer Duty and learn more about how it is different to Treating Customers Fairly, where 3mc as a Packager can help brokers with Consumer Duty and what a Broker needs to be thinking about in terms of actions and deadlines.


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