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‘We want to ensure that the process of complaining is straightforward, transparent and fair to consumers, while allowing firms to handle complaints as efficiently as possible and for consumers to have effective access to the ombudsman service if they remain dissatisfied.’ Financial Conduct Authority (FCA)

How firms handle complaints continues to be a key area of focus for the FCA across all financial services sectors and particularly in relation to the Consumer Credit sector. The FCA aims to encourage quick, informal resolutions in line with an ‘outcomes-led’ approach to regulation placing emphasis on the customer journey. For many firms who are transitioning towards or are new to FCA regulation, this change represents an additional challenge which is critical in establishing their relationship with the regulator.

From the 30 June 2016, many of the FCA’s revised complaint handling regulations (PS15/19) came in to force, impacting firms’ complaint handling processes and regulatory reporting. These changes have raised a number of challenges for firms in securing reporting accuracy and ensuring full compliance with FCA regulation and expectation.

Challenges faced by firms

  • Increased risk of supervisory or enforcement action as the FCA adopts a zero tolerance approach to incorrect reporting. As such recording and reporting methodologies need to be robust to ensure accurate capture of customer complaints.
  • The FCA’s definition of a complaint can be interpreted widely, especially around the question of ‘material distress or inconvenience’. Firms must ensure their front-line teams are clear on what constitutes a ‘complaint’ versus ‘feedback’ to avoid over-reporting and increased costs.
  • Firms who have historically resolved a high proportion of their complaints by next working day (which would not previously have been reported) may now be faced with a sudden increase in the volume of reportable complaints. This increase could lead to negative media or consumer reaction which the firm will need to manage.
  • The requirement to issue the ‘summary resolution communication’ creates an additional step in the complaint process, which may increase the costs and requirements for control around early complaint resolution.
  • As the ‘summary resolution communication’ must include details of the Financial Ombudsman Service (FOS) – this could increase the number of referrals incurring FOS fees and also time spent dealing with the FOS.

Five key areas of focus

A firm’s complaint handling procedures and reporting must be able to withstand regulatory scrutiny, whilst ensuring that both the firm and their customers are receiving the correct outcomes. With this in mind, we have defined five key areas to look at when assessing your operation against the new rules:

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Firms should now have implemented changes in order to adapt their procedures to new regulations. At this point it may be helpful to receive independent corroboration that the changes made are effective and are delivering the required outcomes.

Our deep regulatory knowledge and industry expertise mean that we are ideally placed to provide this assurance for you by reviewing the effectiveness of the five key areas of focus discussed above and determining how these operate in practice. Our solutions are made up of a number of components that can be applied in isolation or as a package, enabling us to provide a fully bespoke solution designed for your business. These components provide insight into the key focus areas outlined above as indicated below:

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Following completion of the review we will provide a detailed, constructive feedback report on our observations. This report will draw on industry insights we have gained from other similar projects and will include recommended improvement approaches that are pragmatic, flexible and capable of implementation. 

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Elizabeth Haran - Senior Manager, Risk and Regulation, Deloitte

Elizabeth has over fifteen years of experience working with a variety of firms across the Financial Services sector with specialist experience in Compliance and Conduct Risk issues, she leads Deloitte’s regional Consumer Credit Practice.

Email | LinkedIn

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Sarah Ballance - Senior Manager, Risk Advisory, Deloitte

Sarah is a Senior Manager in Deloitte’s Risk Advisory Group. Based in the North of England, she has 14 years of experience in Financial Services working with Banks, Building Societies and Consumer Credit Firms.

Email | LinkedIn

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Peter Birch - Partner, Advisory practice, Deloitte

Peter leads Deloitte’s National Non-Standard Lending practice, (which includes all unsecured lenders), and our Risk and Regulation Practice in the North of England. With 10 years of experience working with a variety of businesses across the financial services sector, including retail and commercial banks, specialist lending businesses, building societies, intermediaries and investment businesses.

Email | LinkedIn

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