View
465
Download
0
Category
Preview:
Citation preview
Could small complaints give you a
big headache?
Bovill briefing
22 October 2015
Neil Walkling & Max Young
2
Agenda
1. New complaint handling rules: what’s changing and why?
2. Summary resolution communication
3. Challenges to front-line staff posed by the new complaint-handling
regime
4. Impact of the wider ‘eligible complainant’ definition on firms with
professional clients
5. Changes to complaint reporting
6. Monitoring and control
7. Takeaways
3
New complaint handling rules (PS15/19)
What’s changing? Why? When?
More time to handle complaints informally:
3 business days after date of receipt
Allow easier and speedier
resolution of more
complaints
30/6/16
All complaints will be reportable to FCA –
even those resolved informally within 3
business days
Improve completeness,
comparability, and
transparency of data
30/6/16
Issue summary resolution communication if
resolved within 3 business days – including
option of going directly to FOS
Encourage firms to handle
complaints properly first
time – not fob people off
30/6/16
Limit on cost of calls to existing customers
(not just complainants) to ‘basic rate’
Prevent firms from making
money from calls and/or
deterring customers from
calling to resolve issues
26/10/15
4
Summary Resolution Communication
Must be issued when the complaint has been informally resolved,
without triggering a full investigation or final response letter
For example:
complaint received Monday
informally resolved COB Thursday
5
Prescribed content of communication
• Firm considers the complaint to be resolved
• Can refer complaint to FOS if subsequently decide they are
dissatisfied
• Website address for the FOS, and further info is available there
• Whether firm consents to waive 6 month time limit for referring
complaint to FOS
6
Possible extra content in communication
• Encourage customer to refer back to us first if still unhappy (but
must not undermine key message about right to complain to FOS)
• FCA envisages generic template, but firms could choose to add
personalised content (e.g. about the complaint and how it was
resolved)
7
What would your clients make of this?
Your recent complaint to ABC Ltd
Dear Customer [Dear Mr X]
The purpose of this notice is to confirm that we consider that your recent complaint to us has been
resolved to your satisfaction.
If you decide that you remain dissatisfied, you have the right to refer your complaint to the
Financial Ombudsman Service (FOS), free of charge – but you must do so within six months of the
date of this letter. The FOS website address is http://financial-ombudsman.org.uk/ and you can
find further information there.
If you are not happy with the way we resolved your complaint, we would appreciate the opportunity to put
things right for you, so please do let us know as soon as possible by calling XXXXXXX on YYYYYYYYY.
We’re sorry that you felt the need to complain in the first place, but we’re grateful to you for bringing the
matter to our attention. We endeavour to provide the best possible service, and welcome feedback from
clients about where we might be going wrong and how we can improve.
8
Summary resolution statement: minimalist/ tailored?
Advantages Disadvantages
Encourage
customer to
come back to
firm first, if still
unhappy
Fewer cases reach FOS
Deal with genuine misunderstandings
before they do more damage
Signal to customers that you take
complaints seriously
Quicker resolution and less hassle for
customer?
Was the summary communication
statement really your final response?
Danger of ‘two-stage process’
mentality creeping in
Personalise the
content of the
communication
for each
customer
Standard template may cause
irritation, especially if expectations
not managed
Make customers feel special and
valued – strengthen relationship
May be helpful for audit trail, root
cause analysis, accuracy of
complaints data
Disproportionate extra work/effort to
resolve minor gripes?
Quality control/sign-off issues
Risk of breaching the 3-day deadline
for informal resolution
Effectively a final response letter?
9
New challenges for your frontline staff?
Identifying
• More onus to identify which issues raised by customers should be treated as complaints
• Some (mainly larger?) firms already capture MI on informally resolved complaints for root cause analysis
• Possible conflicts of interest (incentives/performance management)?
Reporting
• Decide how to categorise/report the complaint
• System for reporting/collating the data for complaints informally resolved on front line?
Summary resolution
communication
• Check that customer is really satisfied with resolution
• Inform customers and manage expectations about the impending communication
• On the spot decision on whether to treat as complaint or not likely to be required
• Role in issuing the communication?
…on top of resolving the complaint appropriately,
or deciding whether it should be escalated
10
What is a complaint?
(a) “Any oral or written expression of dissatisfaction, whether
justified or not, from, or on behalf of, a person about the
provision of, or failure to provide, a financial service or a
redress determination, which:
(a) Alleges that the complainant has suffered (or may suffer)
financial loss, material distress or material inconvenience;
and
(b) relates to an activity of that respondent, or of any other
respondent with whom that respondent has some
connection in marketing or providing financial services or
products, which comes under the jurisdiction of the Financial
Ombudsman Service”.
11
Is this a complaint?
1. Email from client:
Hi Amy
I don’t seem to have received my portfolio statement yet, and it has
normally arrived by this time of the month. Could you let me know
what’s happened to it?
Thanks
2. Telephone conversation with client:
I’m not happy with the recent performance of my portfolio – makes
me wonder why I’m paying you all these fees.
3. Face-to-face conversation with client: their first visit to the office
since it was refurbished:
I don’t like your new layout, I preferred it the way it was. I suppose I’ll
end up paying for this waste of money through higher charges?
12
Is this a complaint?
4. Letter from client:
I don’t feel the performance of my portfolio is good enough to justify the
fees I’m paying, so I’ve decided to close my account with you and move
my investments to Butch Cassidy & Partners
5. Telephone conversation with client about ID requirements:
I don’t understand why I need to make a special journey into your office
to show you my passport and bank statements - you’ve known me for 20
years.
6. Face-to-face conversation with client about their experience of dealing
with a call centre based in a particular region of the UK:
I’ve come in to the branch to make the amendments because I’ve given
up trying to deal with your call centre. Their accents are so strong that I
can’t understand a word they say, even after asking them to repeat
everything several times.
13
Is this a complaint?
7. Telephone conversation between client and manager of his local office:
Most of your staff are foreigners – you should be employing local people.
Lots of youngsters round here are unemployed.
8. Email from client:
Hi John
Could I have an urgent update on my transaction please? It seems to be
taking forever and you haven’t responded to the chaser email I sent on
Monday.
9. Telephone conversation with client about 15 page suitability report he’s
just received:
Do I really need to read this report? I haven’t got the time or inclination -
you’re supposed to be the expert so I should be able to rely on your
advice without having to wade through an impenetrable tome that you’ve
churned out to keep your compliance people happy.
14
Is this a complaint?
10. Email from client:
Hi Mary
Could you give me a call to discuss the invoice you sent recently? I think
you’ve overcharged me.
Thanks
11. Telephone conversation with client about arrangements for financial
advice review meeting:
I really don’t see why you’re insisting that my wife should come along to
the meeting. She’s not interested in the financial stuff, and is happy to
leave it to me to sort out.
12. Telephone conversation with client:
By the way, you forgot to attach the document I need to sign with that
email you sent me yesterday.
16
Eligible Complainants – FOS net widens
DISP 2.7.9 – Professional clients and eligible counterparties not
considered eligible complainants
NEW ADDITIONAL RULE
DISP 2.7.9A (from 9 July 2015) – the above does not apply to a
complainant who is a consumer relation to the activity in which the
complaint relates
17
Are my professional clients ‘consumers’?
Consumer = “a natural person acting for purposes outside their
trade, business or profession”
18
Eligible complainants – Key impacts
• Client categorisation and take-on
• Client agreement/TOB
• Complaint handling procedure
• FOS fees and levies
• DISP Rules application
20
Summary of changes to FCA complaint return
Informally resolved
complaints
• Included for first
time
• Complaint and
product categories
mirror those for
formal complaints
More Granularity
• New investment
types added to
return
Other changes to complaint return
• Extra guidance
21
FCA Reporting – the timeframes
New return format:
Return due on or after 30th June 2016
Needs to start recording informal complaints from 6 months before
this and ensure you can report right level of detail
22
FCA Reporting – Important to note
• Some firms submitting reports of complaints for the first time
• Firms must maintain records for up to five years
• No complaints to report…is this credible?
23
Complaints data – inform FCA thematic?
• FCA will expect number of reported complaints to rise
• How can you (or FCA) tell whether you have
implemented the new regime properly?
24
Are your staff getting it right?
Staff awareness
Training/briefing records
Policies & procedures
Call listening
End-to-end audit trail:
Identification, categorisation, summary resolution
communication
Timing – 3 day limit?
Client file reviews (e.g. suitability)
Evidence of complaints on file?
Testing
26
A few questions to consider
1. How will you train your customer-facing staff on identifying, handling and
recording day-to-day minor gripes that don’t require an investigation
2. How will staff report complaints they resolve on the spot?
3. Who will issue the summary resolution communication, and in what medium?
4. What will your summary resolution statement look like?
5. How can you minimise the risk of the summary resolution statement annoying
your clients?
6. When do you need to start recording informally handled complaints to be ready
to report them for the first time?
7. How are you effected by the wider eligible complainant definition, and what are
you doing about it?
8. How can you test whether the number of informal complaints your firm report
reflects the true picture?
Recommended