PRIN 2A.6 – Consumer Support Rules
PRIN 2A.6 sets out the rules which ensure that retail customers receive appropriate support throughout their relationship with financial services firms, from initial enquiries through to cancellation or complaints. The rules apply to all firms covered by Principle 12 and the Consumer Duty, focusing on direct customer interactions and support functions, whether delivered in-house or outsourced.
Rule PRIN 2A.6.1R – Application
Who these rules apply to:
These consumer support rules apply to all firms that are subject to Principle 12 and the Consumer Duty regulations, specifically when they:
- Directly interact with and provide support to retail customers (including through customer service teams)
- Use any communication channel to support customers (phone, email, social media, etc.)
- Outsource their customer interactions to third parties
- Provide any form of customer service or support
The only exception is rule PRIN 2A.6.6R, which applies more broadly to all firms covered by the Consumer Duty.
Rule PRIN 2A.6.2R – Design and Delivery of Customer Support
How firms must design their customer support:
Firms must create and deliver customer support that achieves four key outcomes:
1. Meeting customer needs – The support must work for all retail customers, including those who may be vulnerable or have special characteristics that require additional consideration.
2. Enabling product use – Customers must be able to use their financial products in the way they would reasonably expect to, without unnecessary obstacles.
3. Including protective friction – Where appropriate, firms should build in deliberate steps or checks in customer journeys to prevent harm and give customers time to understand their options and any risks involved.
4. Removing unreasonable barriers – Customers should not face unnecessary obstacles or costs when they want to:
- Make general enquiries or requests
- Change or switch their product
- Transfer to a new provider
- Access benefits their product is meant to provide
- Submit claims
- Make complaints
- Cancel contracts or end their relationship with the firm
Rule PRIN 2A.6.3R – What Counts as Unreasonable Barriers
Understanding unreasonable barriers:
Unreasonable barriers are obstacles that force customers to take unnecessary extra steps, including:
- Processes that are overly difficult, time-consuming, or complex
- Steps that are hard for customers to understand
- Requests for unnecessary information or evidence
- Unreasonable exit fees, delays, distress, or inconvenience
Important note: Protective friction that prevents harm (as required in rule 2A.6.2R(3)) is not considered an unreasonable barrier.
Rule PRIN 2A.6.4R – Examples of Poor Support
What firms should avoid:
Firms are unlikely to meet their customer support obligations if their practices cause or would likely cause:
1. Unfair prioritization – Giving better service to potential new customers than to existing customers
2. Unreasonable delays in customer contact – Such as making customers wait much longer to cancel a product than to buy one
3. Unreasonable delays in processing:
- Payments owed to customers after they’ve been agreed
- Requesting necessary information from customers
- Processing information customers have provided
Rule PRIN 2A.6.5R – Dealing with Representatives
Supporting authorized representatives:
When someone is legally authorized to help a retail customer with their affairs (such as someone with power of attorney), firms must provide the same level of support to that representative as they would to the customer themselves.
Exception: This rule doesn’t apply when the person helping the customer is also a regulated firm.
Rule PRIN 2A.6.6R – Dealing with Requests from Other Firms
Inter-firm cooperation:
All firms covered by the Consumer Duty must handle reasonable requests from other firms effectively and promptly. This cooperation enables other firms to properly support their retail customers.
This rule applies to all firms under the Consumer Duty, not just those directly providing customer support.