Why your lead follow-up process is now a compliance question, not just a commercial one.
Most insurance brokers have spent the last two years thinking about Consumer Duty in terms of product suitability, fair value, and customer communications. Few have thought about what it means for the moment before any of that begins.
The moment a lead arrives matters more than most firms realise. And the FCA is increasingly paying attention to it.
What Consumer Duty Actually Requires
Introduced by the FCA in July 2023, Consumer Duty sets a higher standard of care for firms dealing with retail customers. It goes beyond following rules to asking a harder question: can you demonstrate that your customers received a good outcome?
For insurance brokers, that expectation applies across the entire customer journey. Not just the advice. Not just the suitability letter. The whole thing, from the moment an enquiry arrives to the moment a case closes.
Which means the follow-up process is no longer just a commercial concern. It is a compliance one
What the FCA Is Now Looking For
Here are the problems most small insurance brokerages have not yet confronted.
An enquiry arrives. Someone picks it up when they can. The first contact might be prompt. It might not be. On a busy day, it might be significantly later than the customer expected.
In many small brokerages, that journey exists in people’s heads rather than in a system. No timestamp on the first attempt. No log of how many times contact was made. No documented record of what happened between the lead arriving and the adviser making contact.
Under Consumer Duty, the FCA expects firms to show they acted in the customer’s interest throughout the journey. An enquiry that sat uncontacted and unlogged while the customer was still actively looking is not evidence of a good outcome. It is evidence of a process that was not built to produce one.
The FCA has been clear that it will evaluate all customer interactions, with particular emphasis on timeliness and the quality of the customer journey from first contact onwards
The Compliance and Commercial Arguments Are the Same Argument
A customer who submits an insurance enquiry is deciding in real time. The broker who makes prompt, documented contact is in the best position to help them. The broker whose process relies on memory and availability is not.
That is a conversion problem; however, under Consumer Duty, it is also a regulatory one. A customer who did not receive timely, evidenced contact from a firm that could help them is a customer the FCA may consider was not well served.
The firms that convert consistently and carry the least regulatory exposure tend to have built the same thing: a process that makes fast, documented, consistent contact the automatic default, not the best-case outcome.
What a Defensible Process Looks Like
Where Consumer Duty does not require perfection, it does require evidence. For an insurance company, a process that the FCA could inspect and defend has three characteristics.
Every enquiry is captured and timestamped automatically from every source the moment it arrives. Not logged later, but captured at the point of receipt, with a clear record of origin and time.
Leads are assigned to a named adviser immediately, with no manual handoff and no window in which a lead exists, but nobody owns it.
Contact attempts, follow-ups, and outcomes are logged by the system rather than by the person. If the FCA ever asked to see the journey an enquiry took from arrival to outcome, the answer is in the system, not in someone’s memory.
The Fact Find Is a Compliance Document Too
The duty to act in customers’ interests doesn’t end with the advice. It runs through the entire journey. In an insurance context, that includes identifying relevant needs a customer may not have raised themselves.
A customer who enquires about life cover may have an unmet need for income protection or critical illness cover. A structured fact find that surfaces those questions systematically, records the answers, and triggers the appropriate follow-up conversations is both good practice and the kind of documented, outcome-focused process Consumer Duty points toward.
How FLG Helps Insurance Brokers Build This Process
FLG captures enquiries from every source automatically, assigns them immediately, and logs every contact attempt and outcome without relying on anyone to remember to do it. The audit trail is built into the process rather than added as an afterthought. You can see how that works in practice on our insurance broker’s page.
For firms working across life, protection, and income products, FLG’s structured fact finds surface cross-sell opportunities based on customer answers rather than adviser memory. Every recommendation is supported by a documented journey that the firm can evidence.
Renewal reminders are one of the highest-value touchpoints in an insurance relationship. We’ve written about how planned campaigns protect both revenue and compliance in our article on bulk email scheduling.
And if your contact data hasn’t been validated recently, your renewal communications may not be reaching the customers they’re intended for. Our article on data cleansing covers the cost and how straightforward the fix is.
The Bottom Line Is
For insurance brokers, the bar has moved. The question is no longer only whether the advice was useful. It is whether the entire journey can be evidenced as one that served the customer’s interests. A process built to do that tends to convert better, too. The two are the same thing.