Restricted advisers should consider whether their customers have needs in areas they cannot service, and if so, what their disclosures, notification and referral processes are around this.

Protection advice, for example, is a common area many investment and wealth advisers shy away from, however there is often a need for their customers. Firms need to establish which areas they are advising on, and what to do with the areas they are not.

When selling products, advisers will need to think carefully about their fees and charging structures and how they demonstrate value.  

The cost of a product or service must be fair. It is not uncommon for customers to pay for an ongoing service, with an annual review and charge, but for this service not to be delivered as initially described.

This is an area that can easily be targeted by the regulator, but equally one that can easily be rectified by firms.

When reviewing and delivering their services, advisers should outline exactly what a customer can expect in their terms and conditions, and then deliver on it.

Advisers need to think in detail about their strategies for customer engagement: how best to engage with customers, through what channels, and using what language.

How are products and services articulated to customers who may not be financially experienced or literate, or are vulnerable?

Advisers should be able to adapt their processes to meet the information needs of their customers as well as be prepared to engage with them through the channels they are most comfortable with. 

While digital consumer journeys are increasingly prevalent in the market, advisers will need to think about the risks that they carry and how these are managed and mitigated.

Increasingly, advisers are relying on hybrid or virtual advice, but they will need to show why they consider that engagement model to be appropriate for their customers.

First and foremost, if advisers and firms can get in the mindset of the consumer duty, and think about achieving good consumer outcomes in everything they do – engraining the approach within their culture day-to-day, front and back office, evidencing the activity along the way – they will have one foot forward.

The consumer duty aims to uplift standards across the entire operating model and ensure consumers are put ahead of any other strategic drivers.

Simon Goryl is a consultant at Bovill