Frequently Asked Questions

At Kyshi, we continue to meet our regulatory responsibilities. When the FCA published the Consumer Duty final rules and guidance in 2022, an implementation plan was created and approved by the Board. We are aware that the implementation will commence on 31 July 2023 and have put plans in place to comply with the deadline.

In addition to a general overview of the work we are completing on Consumer Duty, documentation under each of the four areas (1. Products and Services; 2. Price and Value; 3. Consumer Understanding; 4. Consumer Support) will be available. This documentation and support includes:

• Product Information and Approval Documents (where applicable)  
• Product Information document
• information covering key product characteristics, target market, who the product is suitable and unsuitable for and key exclusions.  
• Fair Value Assessment Outcomes  
• Contact details for our support team on various platforms such as email, WhatsApp and social media platforms  

 In addition to other documentation, we will provide:

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   1. Documentation setting out the good customer outcomes and the management information used to assess whether they have been delivered at a product level for key areas 1 and 2 above.  
   2. Documentation setting out the good customer outcomes and the management information used to assess whether they have been delivered at a more general level for key areas 3 and 4 above.  

Consumer duty applies to a wider scope of customers than just ‘retail consumers’. We aim to provide good customer outcomes for all our customers and review both specific management information for our products.

For each of the four key areas, we have assessed what we understand the customer would consider a good outcome.    

These identified outcomes are:  

Product and Services 

• Customers are provided with a product that meets their needs  
• Customers are provided with a product that is appropriate and meets their expectations  
• Customers are provided with clear and easy-to-understand products  

Price and Value  

• Customers are provided with a product where the price is fair  
• Customers are provided with a product where the costs do not adversely affect the product’s value  

Consumer Understanding and Consumer Support  

• Customers view marketing content that is clear, fair and not misleading.  
• Customers deal with our contact support team are well-informed and understand our products.  
• Customers that are vulnerable are identified and appropriate adjustments are made.  
• Customers are provided with all the necessary information to make an informed decision.  
• Customers receive relevant information in a timely manner.  
• Customers' individual needs are considered when they use our product.  
• Customers can understand all of the terms and conditions of the product and understand their obligation.  
• Customers are responded to in a timely manner and in an appropriate way.  
• Customers clearly understand how to request an account upgrade and how to access any feature on the app.  
• Customers clearly understand how to make a complaint and what happens next.  
• Customers have easy access to making a complaint, the channels to follow and are well-informed throughout the process.  
• Customers are satisfied with how they are dealt with when making a complaint.  

To assess whether a good outcome has been delivered, we look at both qualitative and quantitative information. We have identified key management information that is relevant for each of the outcomes listed above, this management information includes but is not limited to:

• Customer reviews and feedbacks  
• Product reviews including testing of the customer journey  
• Fair value assessments  
• Retention rates  
• Complaints data  
• Transactions data  
• Account closures  
• Active accounts data  

Since the introduction of the FCA Pricing Practices, we have focused on viewing our products from a customer perspective, particularly looking at providing fair value. The Consumer Duty Regulations have meant we have further defined what good customer outcomes look like and how we can measure our performance against them.

During product development, we document the customer journey to ensure that the product design, testing and eventual launch are meeting the needs of the intended targeted customers. This customer journey testing moves through the customer experience at onboarding stage, account activation, transaction experience, account closure, and making complaints. It is imperative for us to ensure that each stage is appropriate and efficient as it can be and does not cause any reasonably foreseeable harm.

We have updated our vulnerable customers’ policy and producing further documentation so that our partners can understand our approach more fully. It is essential that vulnerable customers are considered at every point of the customer journey, at the product design stage and throughout the product lifecycle. The FCA ‘Guidance for firms for the treatment of vulnerable customers’ sets out the key areas of consideration and how adjustments can be made.

Yes, a ‘Consumer Duty Champion’ has been appointed at Board level and the key issues are discussed at senior management and Board level. We ensure that the customer journey and good customer outcomes are central to the way we operate.

The Consumer Duty principle “a firm must act to deliver good outcomes for consumers” is being embedded into our product management lifecycle, to enable us:  

• Act in good faith toward retail customers.  
• Avoid foreseeable harm to retail customers.  
• Enable and support retail customers to pursue their financial objectives.    
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Fair Value Assessments and product reviews will be updated to ensure that we’ve taken into account the good customer outcomes we’ve identified as critical. As with the FCA regulations stated in PROD4, Consumer Duty will be at the forefront of our design, testing, approval, distribution and monitoring.    

Alongside the Board oversight, we will be tracking Consumer Duty within our management review meetings. We will regularly review performance against the identified good customer outcomes using the management information we’ve identified as relevant for each area. Training will also be provided to all our employees to ensure they are knowledgeable and informed.  

The most significant change is the way the management information (MI) is collected, extracted and reviewed. The aim of this is to create robust MI and customer insights to evidence that we are complying with the principle of Consumer Duty.

We are updating our website with Consumer Duty information to provide our customers with additional useful resource. Here you may be able to access resources such as product information and our various services. We will also be able to provide any specific details required on request.

We are on track to implement the Consumer Duty requirements by the deadline date of 31 July 2023.

We are committed to working collaboratively with our partners to ensure that we provide the best customer experience. Our staff are knowledgeable about the products we provide and we will ensure that the product is suitable for the customer. We also expect that vulnerable customers are identified in order for any suitable adjustments to be made. Additionally, any fees and charges added to the product should be reasonable and should not affect the value of the product.    

Please contact our customer support team via any of our communication channels available on the mobile app or contact us via the website or alternatively, contact our compliance team on hello@kyshi.co