"Ask the client, 'what could I do to make you read this report?' Don't make assumptions. This is what this consumer duty is about. We're making assumptions all the time. This is saying 'no, you can't make assumptions, get to the nub of it," she says.
Holman says frequently asked questions can be a great way to engage with the client as it makes the conversation about the client and their questions.
"It's so much more engaging. So 'client agreement', [can instead be] 'what can we do for you' [...] 'what do I do if I'm not happy' [can be used] rather than 'complaints', and you can still make something absolutely compliant but not using legal jargon, regulatory jargon," she says.
"If I've got a report that's full of legal jargon, it's compliant, technically correct, absolutely. But yet I'm sitting here in front of you, effing and jeffing, the tone of the letter does not reflect how I'm speaking to you now.
"That's where a lot of the clients get a bit confused and therefore do not want to read the letter. If the tone of your letter, or what that looks like, reflects how I communicate with you, then I know it's for me. So that is a shift, that's a lot of work for firms to get their head around."
While some companies have been actively innovating around their communications, others have not quite grasped what the duty is asking of them, Holman says. "Some firms have been really awesome at this and really spend a lot of time with it, other firms are maybe perhaps missing a trick. So I think that's a big piece."
She adds: "There'll be stuff that happens, there'll be the odd slip up, but that's life, that's business. But it's all about how you hold yourself out and your culture and your integrity.
"And the firms that have got good practices and processes in place are more efficient, they're not running round like headless chickens, they're busy, but then everybody knows what they've got to do, they're accountable to it. And it's not like 'ah I thought so and so was doing it'."
Find out more
To view FTAdviser's consumer duty hub, click here.
carmen.reichman@ft.com
