Consumer Duty – here are answers to 10 common questions about the Duty and IPM

Over the last few months, financial firms across the UK have been preparing for Consumer Duty. We’ve also been working hard to ensure that we continue to deliver great outcomes for retail customers. 

As a “manufacturer”, IPM has been looking at our business with the Duty in mind and making appropriate changes. We have also been considering what this will mean for our relationships with advisers (“distributors”) and how best we can assist adviser firms to satisfy their Consumer Duty requirements. 

To help you understand our role, and how we can support you and your clients, here are answers to 10 common Consumer Duty questions.

1. What does Consumer Duty mean for the IPM SIPP?

Helping our members to thrive in retirement has always been at the heart of our business, so the fundamentals of Consumer Duty are not new to us. 

We provide:

  • Dedicated customer service
  • Clear and simple pricing
  • Easy-to-read and accessible literature
  • Experienced and highly technical administration and property teams.

We completed the manufacturer reviews necessary to meet the outcome rules for our SIPP. We have shared these in our Target Market Statement and Fair Value Assessment documents to help financial advisers (distributors) meet their obligations and identify if and where any changes need to be made.

2. How do I find your Target Market Statement and Fair Value Assessment?

These are available on our website by following the links:

3. How closely do I need to follow your Target Market Statement?

The statement tells you who we’ve defined as the target market for our product and who we think the product is suitable for. 

You should ensure that the way in which you distribute the product aligns with customers within the target market. You also need to regularly check that the way in which you’re distributing the product aligns with customers in the target market. 

If you wish to recommend our SIPP to a customer who you have identified as being in our negative target market, please contact us to discuss the details. Our SIPP may still offer fair value to your client, depending on the circumstances.

4. Do I need to check IPM’s Fair Value Assessment?

Distributors only need to ensure that the product continues to offer fair value when you add your charges for distributing products or services. 

We have tried to include information in our value assessment to reflect this. All firms in the distribution chain are responsible for the value of the prices they control.

5. How often will IPM review their Target Market Statement and Fair Value Assessment?

We will conduct reviews annually. 

Our assessment of fair value, and whether new SIPPs are within our target market, has been incorporated into our management information.

6. The FCA say that IPM should review their agreements with distributors. When will you contact us about this and what is required from us?

We have made changes to our Terms of Business documents as part of our work in the lead up to the Consumer Duty. We will roll these out to distributors in the near future.

7. If you have found your product doesn’t offer fair value to customers, what will you be doing?

We are satisfied that the IPM SIPP continues to offer fair value to consumers within our identified target market.  

8. How will Consumer Duty affect the communications you issue to customers?

Consumer Duty requires that customers are provided with the information they need, at the right time, and that it is presented in a way they can understand. This is to support and enable informed decisions about financial products and services.

We have recently enhanced our online access to our members to enable us to communicate easily and provide effective support and information. 

The enhancement also allows us to request regular feedback from our members to ensure that their needs are being met.

9. How is IPM embedding Consumer Duty principles into your business?

We implemented a Consumer Duty Project to review our communications, processes, risks, and customer journeys. Our aim is to ensure we deliver all outcomes in line with the Duty.

We have also started a programme of Consumer Duty training with our administration team. The aim of this is to ensure that any changes to our processes are fully embedded as part of the Consumer Duty culture.

10. How has Consumer Duty changed the support that IPM provides to customers in vulnerable circumstances?

Our SIPP is used by a broad range of customers, and we recognise that, at any time, our customers’ personal circumstances can cause them to exhibit characteristics of vulnerability. We are asking both our customers and distributors to let us know when there is a need for additional or tailored support.

As part of our Consumer Duty reviews, we have re-examined the support we provide to customers in vulnerable circumstances. We have incorporated considerations around vulnerability into our communications, service, and product review. We have also reached out to external organisations, such as Scope and Age UK, to ask how our service can be tailored to further support those with additional needs.            

Get in touch

If you have any questions about how Consumer Duty affects you or your clients, please get in touch and we’ll be happy to help.

Email or call 01438 747151.

Get in touch

Whether it’s a question about a specific client or SIPPs in general, we are here to help. Call us on 01438 747 151, email or complete the form below: