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  1. Consumer duty
  2. Hormone Replacement Therapy (HRT)
  3. Levelling Up
  4. Population Health Management
  5. Access to cash

Consumer duty

Background

In 2018 the Financial Conduct Authority began a series of consultations to strengthen consumer protection, recognising that ‘the extent and long-standing nature of consumer detriment indicate that cultural change is required within firms and the market as a whole.

In 2021 the FCA proposed ‘a new Consumer Duty’, a reformed regulatory structure to tackle consumer harms. The FCA highlights harms such as exploiting consumers’ behavioural biases, offering products that do not meet consumer needs, discouraging consumers from leaving unsuitable products or services, and poor customer service.

IFoA view

The IFoA supports the FCA’s focus on outcomes rather than compliance with rules, on enabling better decisions, and on the needs of consumers, especially vulnerable ones. We agree with the FCA that the four key elements of the firm-consumer relationship are communications, products and services, customer service, and price and value. We have highlighted the risk that some consumers may not like ‘good outcomes’, preferring ‘low prices in the short term’, and the proposals may have to allow such customers to insist on bad choices.

The FCA intends to use levers such as fines for firms and redress for consumers to tackle serious misconduct regarding Consumer Duty. We have proposed that the FCA should apply sanctions against individuals for breaches that lead to widespread poor outcomes.

Further resources

Hormone Replacement Therapy (HRT)

Background

A study commissioned by the Institute and Faculty of Actuaries (IFoA) and undertaken by researchers at the University of East Anglia (UEA) has found that hormone replacement therapy (HRT) could boost life expectancy among healthy women. The study is the first of its kind to look at the impact of HRT on overall life expectancy using UK primary care data. It followed 105,199 healthy women aged 46 to 65 years at first HRT prescription over up to 32 years with an average follow-up of 13 years and compared their outcomes with 224,643 non-users of the same age and GP practice. This positive data is especially important because HRT use has been controversial for many years, due to conflicting reports about the long-term risk of breast cancer. This research strengthens the emerging consensus that for most women the benefits of long-term HRT outweigh the harms.

What to look out for

Ahead of the Second Reading of the Menopause (Support and Services) Bill on Friday 29 October 2021, the IFoA sent a briefing document to interested parliamentarians, including members of the All-Party Parliamentary Group (APPG) on Menopause. The group has subsequently confirmed that it will take the report into consideration as part of its latest inquiry into HRT.

Further resources

  • The full research article is available via the British Journal of Obstetrics and Gynaecology.
  • A summary of the major findings and comments from the IFoA and UEA is also available on our website.

Levelling Up

Background

The ‘Levelling Up’ agenda first emerged in the 2019 Conservative Manifesto and has since become a central plank of its policy agenda in Government. The rationale behind Levelling Up infers that some areas of the UK have been ‘left behind' and that as a result, the communities living in those areas are not able to access the same opportunities as those who have benefitted from the greater public (and private) investment elsewhere. This ranges from a lack of investment in transport and infrastructure to inequalities in areas such as education, jobs, skills, pay and healthcare.

IFoA view on Levelling Up

The Government’s long-awaited White Paper on Levelling Up was published in February 2022. In its response to the White paper, the IFoA has welcomed its focus on widening opportunity while also stressing that the Levelling-Up agenda should increase individuals’ financial resilience. 

For the actuarial profession, the Levelling Up agenda is most likely to intersect with the IFoA’s work on infrastructure investment and health. Taking infrastructure as an example, the creation of the £4.8bn Levelling Up Fund aims to support investment in town centres and local transport networks. The IFoA welcomed this and will work with Government to share our relevant expertise to overcome some of the challenges that inhibit prospective investors from taking on more projects.

On the health side, the Actuarial Research Centre-funded Longevity and Morbidity Risk programme has produced a new bespoke mortality index that highlights mortality inequalities in England. The insights provided by the index could inform policymakers when making spending decisions on healthcare to ensure investment is targeted in the most appropriate places.

Further Reading

Population Health Management

The UK’s National Health Service (NHS) has identified Population Health Management (PHM) as a key component of its long-term plan to develop integrated local healthcare systems that provide the right care at the right place and at the right time. PHM uses data to inform the development of interventions tailored to local at-risk population cohorts, aiming for improved outcomes with reduced unwarranted variation between cohorts.

The IFoA Population Health Management Working Party has been working with the NHS on impactability modelling, and is undertaking further work to build understanding around how actuarial science can support PHM in healthcare systems.

Further reading

Impactability Modelling for Population Health Management A review of current concepts and practices

An impactability modelling framework for population health management with an example for prediabetes

Access to cash

We welcome the Government's announcement of a Financial Services and Markets Bill in the Queen’s Speech in May 2022. We are pleased to see that the Bill will include action to support individuals’ confidence in financial services by ensuring continued access to cash across the UK.

The IFoA has highlighted the importance of managing the process of declining cash usage carefully. We believe the government should ensure that the growing cost of using cash is not passed on to those vulnerable groups that still rely on it. We therefore support the likely inclusion in the Bill of powers for the Bank of England to make the required changes to ensure the sustainability of the cash infrastructure.

We continue to encourage HMT to initiate and deliver a comprehensive transition programme, to ensure as many people as possible are equipped to use electronic payments for a sustainable future.

Further reading

Events calendar

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