1 company confidential do not distribute | © 2014 aptean. all rights reserved. aptean’s crm, erp...

1 Company Confidential Do Not Distribute|© 2014 Aptean. All rights reserved.

Aptean’s CRM, ERP and Supply Chain software applications enable nearly 5,000 customers to satisfy their customers, operate more efficiently and stay at the forefront of their industry.

Aptean is where software works.

THE RESPOND 2015 USER GROUPFinancial Services

2 Company Confidential Do Not Distribute|

TODAY’S AGENDA

1. The Here and Now, Stuart O’Sullivan (Huntswood)

2. What’s on the Agenda in 2015, Stephen Humphreys (Huntswood)

3. Respond: The Road-Map and Future, Duane George and Eric Brown

4. Thematic Review – Getting Ready for Change (group discussion)

5. Respond User Group - Your Discussion Session

6. Respond Features and Functions, Eric Brown

7. Thematic Review – Getting Ready for Change, Initial Results

8. Post User Group Debrief and Refreshments

Classification: Private – This document and its contents are confidential and

proprietary to Huntswood or its licensors.

No part of this document may be copied, reproduced or transmitted to any third

party in any form without our prior consent.

COMPLAINT HANDLING – THE HERE AND NOW

APTEAN USER GROUP

Presentation by Stuart O’Sullivan

Thursday 5th March 2015

OUR PROPOSITIONS

ADVISORY SERVICES

DEVELOPMENT CENTRES

COMPLAINT EFFECTIVENESS

TRAINING EXPERTS

LEADERSHIP SKILLS

TCF

DESIGN AND IMPLEMENTATION

SENIOR MANAGER’S

REGIME

COMPLIANCE MONITORING

INVESTMENT / MORTGAGE SUITABILITY

FINANCIAL PROMOTIONS

DELIVERY SPECIALISTS

COMPLAINT HANDLING

PAST BUSINESS REVIEW

CUSTOMER REMEDIATION

QUALITY ASSURANCE

OPERATIONAL SUPPORT

MANAGED CLIENT

SERVICES

D

BUSINESS IMPROVEMENT

OPERATIONAL RISK

COMPLIANCE

LEARNING & DEVELOPMENT

RECRUITMENT

PARAPLANNING

NEW BUSINESS CHECKING

SALES AND SERVICE CULTURE

TRAINING AND COMPETENCE

RDR/MMR

ROOT CAUSE ANALYSIS

COMPLAINT HANDLING

SKILLED PERSONS

AGENDA

5

1. Summary of the complaint handling Thematic Review TR 14 / 18

2. Improving complaints handling Consultation Paper CP 14 / 30

3. Practical implications of CP 14 / 30

6

1. SUMMARY OF THE COMPLAINT

HANDLING THEMATIC REVIEW

TR 14 / 18

The regulator’s view

7

“FIRMS HAVE TAKEN STEPS TO IMPROVE THEIR COMPLAINT

HANDLING – BOTH AS A RESULT OF PREVIOUS REGULATORY WORK AND AS A RESULT OF

FIRMS’ OWN INITIATIVE… HOWEVER, IT IS CLEAR THAT

FIRMS COULD – AND SHOULD – DO MORE TO DELIVER FAIR COMPLAINT HANDLING AND

CONSISTENT OUTCOMES FOR ALL CONSUMERS.”

TR 14/18

TR 14 / 18: THE FCA’S APPROACHThis is the first thematic review where the FCA has actively collaborated with target firms.

AIM: to discover where common issues and barriers may exist that prevent effective complaint handling across the group, but also within individual firms.

Methodology: (i) review operating model(s) and management information

(ii) self assessment tasks including QA

(iii) analysis of results (firm and collective level)

(iv) working group created: discuss barriers, ideas for industry improvement

15 major retail firms who handle 90% of all complaints, across all retail sectors took part as well as 5 trade bodies

Activity structured around five key stages of firms’ complaint handling:

1. identifying a complaint 2. recording a complaint 3. internal reporting of a complaint

4. provision of redress 5. carrying out root cause analysis8

TR 14 / 18: WORKING GROUP RECOMMENDATIONS

• Dedicated complaint telephone lines should not use numbers that charge consumers more than a basic rate (including mobile users)

• Reconsider the definition of a complaint (e.g. removing the more subjective element of ‘material’ distress or ‘material’ inconvenience)

• Extend the time frame of the ‘next business day’ rule (e.g. extend to one week)

• Remove the ‘non-reportable’ complaints element of the next business day rule so that firms would report all complaints received

• Review the biannual complaints return to include more consumer centric measures

• Revise the FCA complaints publication (e.g. including more consumer centric measures and contextualised data)

9

TR 14 / 18: ACTIONS FOR ALL FIRMS The FCA stated in TR 14 / 18 that all firms may like to focus on:

• Whether complaint handling policies and processes fully consider whether the interests of consumers are at their heart; avoid a tick-box approach to comply with the DISP rules

• Reviewing internal definition of ‘complaint’ and training staff where the definition is not properly understood

• Whether systems and processes could inhibit accurate recording of complaints, and further consider how this impacts ability to conduct root cause analysis (RCA)

• The observations made about consistency of redress and distress and inconvenience payments

• Considering their approach to RCA – focusing on the observations made in the thematic review paper

• Whether they can make any improvements to their MI (messaging, interpretation, quality metrics and use of targets

10

11

2. IMPROVING COMPLAINTS HANDLING –

CONSULTATION PAPER CP 14 / 30

The regulator’s view

12

“CONSUMERS ARE ENTITLED TO COMPLAIN AND TO SEEK

COMPENSATION FROM FIRMS WHEN THINGS GO WRONG. WE

WANT TO ENSURE THAT THE PROCESS OF COMPLAINING IS

STRAIGHTFORWARD, TRANSPARENT AND FAIR TO

CONSUMERS, WHILE ALLOWING FIRMS TO HANDLE COMPLAINTS AS EFFECTIVELY AS POSSIBLE.”

CP 14/30

IMPROVING COMPLAINTS HANDLING (CP 14/30)

Summary of the proposals within CP 14 / 30:

1. Extend the time period for dealing with a complaint

2. Require firms to send a written communication

3. Ensure firms report and publish all complaints

4. Make general improvements to the ‘complaints return’

5. Limits to the cost of calls to financial services firms

6. Implementing the Alternative Dispute Resolution Directive

The following slides explore 1-3 further

13

EXTEND THE TIME PERIOD FOR DEALING WITH A COMPLAINT

The basic proposal here is to move the current next business day timeframes to the end of three business days

This should bring more customers into the informal process and should allow firms to deal with complaints more quickly and efficiently

The thematic identified a number of problems with trying to force customers quickly through the non reportable route

NBD cut off is currently an 'artificial escalator’ for complaints that could have been dealt with relatively quickly

Sometimes difficult for firms to contact customers to confirm they are content with the resolution

14

REQUIRE FIRMS TO SEND A WRITTEN COMMUNICATION

This communication would be sent to all customers whose complaint is handled by the end of the proposed three business day period

Provides customer with referral rights to FOS if not content

Customers would be able to refer their complaint immediately after the firms response was received, rather than having to wait for 8 weeks to elapse

Will provide important clarity and awareness about their right to refer complaints to the FOS

Thematic review found that customers were not always informed or clear about this escalation route

15

ENSURE FIRMS REPORT AND PUBLISH ALL COMPLAINTS

Remove the distinction between reportable and non-reportable complaints

Will increase transparency around complaints handling – and provide greater comparison

Becomes increasingly important if more complaints are handled within the three business day period

Some serious issues do not surface through the reportable complaints just because they can be dealt with currently by NBD

Reporting changes anticipated by March 2016

16

WORKING PARTY RECOMMENDATIONS VS CP PROPOSALS

17

WORKING PARTY RECOMMENDATION CP PROPOSAL

Dedicated complaint telephone lines should not use numbers that charge consumers more than a ‘basic rate’ (including mobile users)

Taken forward in the new rules limiting the cost of calls to financial services firms

Reconsider the definition of a complaint (e.g. removing the more subjective element of ‘material’ distress or ‘material’ inconvenience

Not taken forward

Extend the time frame of the ‘next business day’ rule (e.g. extend to one week)

Taken forward in proposal to extend the time period for dealing with a complaint by three business days

Remove the ‘non-reportable’ complaints element of the next business day rule so that firms would report all complaints received

Taken forward in proposal for firms to report and publish all complaints

Review the biannual complaints return to include more consumer centric measures

Taken forward in proposal to make general improvements to the ‘complaints return’

Revise the FCA complaints publication (e.g. including more consumer centric measures and contextualised data)

Taken forward in proposal to make general improvements to the ‘complaints return’

18

3. PRACTICAL IMPLICATIONS OF

CP 14 / 30

PRACTICAL IMPLICATIONS OF CP 14 / 30 The deadline for responding to the CP is 13 March 2015.

FCA do take on board feedback and adapt if appropriate

Firms feeling strongly about any of the proposals should respond

The CP mentions that the reporting requirements are due to be implemented in March 2016. This is

therefore likely to be the implementation timetable for other proposals as they are all interrelated. Do

firms feel this is a realistic time frame?

Given the March 2016 implementation timeline, the Policy Statement is likely to be published following

a relatively quick reflection period from CP responses

19

PRACTICAL IMPLICATIONS OF CP 14 / 30 Policy intent of the CP proposals appears sound – however, the devil is always in the

implementation!

The CP does not propose any change to the definition of a complaint: specifically, “financial

loss, material distress and material inconvenience” are to remain.

The proposal appears to be aimed at firms with high volumes of complaints – does this work well

for firms with lower volumes?

The key change, i.e. lengthening NBD and requiring formal communication (and FOS rights) would

seem to prompt a review of a firm’s target operating model where it seeks to accelerate ‘simple’

complaints

20

PRACTICAL IMPLICATIONS OF CP 14 / 30

Some questions:

• Do firms have the right type of staff in the frontline to handle more complaints?

• Are firms confident that front line staff could perform additional responsibilities / handle more

complaints?

• Will closing complaints with a ‘summary resolution letter’ encourage more customers to escalate

their complaint to the FOS?

• Will raising awareness about the Ombudsman Service drive up FOS referral rates?

• Will firms records for complaints closed with a ‘summary resolution letter’ be able to support the

decision made – i.e. do they currently capture enough info for NBD cases?

21

PRACTICAL IMPLICATIONS OF CP 14 / 30

Some questions:

• The FCA is cost benefit analysis states that the cost of training for staff to implement the proposed

changes is cost neutral – do firms think this will be the case?

• Will the changes in reporting requirements require changes to how data is captured by complaint

handlers, i.e. changes in complaint categories, changes in IT?

• Do firms currently capture NBD complaints in the same way / system as reportables? What will the

capture of all complaints mean for RCA going forward?

• How will the increased reporting requirements impact existing operational reporting, MI packs and IT

systems? Will this require greater resource? What will the impact be on governance oversight?

22

Classification: Private – This proposal document and its contents are

confidential and proprietary to Huntswood or its licensors.



QUESTIONS



Classification: Private – This proposal document and its contents are

confidential and proprietary to Huntswood or its licensors.



THANK YOU







COMPLAINT HANDLING

What’s on the agenda in 2015?

Presentation by Stephen Humphreys

5 March 2015

AGENDA

26

Discussion on the future direction and considerations for complaint handling in 2015.

THE 2015 COMPLAINTS OUTLOOK

AGENDA

27

1. Governance, Management Information MI and ensuring effective oversight - Senior Managers Regime (SMR) & Complaints

2. Complaints, quality assurance and outcomes testing – how to demonstrate you’re delivering fair complaint outcomes

3. Vulnerable customers and complaints

28

1. GOVERNANCE, MI AND ENSURING

EFFECTIVE OVERSIGHT

SMR & Complaints

SENIOR MANAGERS REGIME

29

SCOPE AND REACHCurrent Scope of

APER/SUP10A

Relevant committee chair

FCA Approved Persons

PRA Approved Persons

ChairmanExecutive Board (Plus

wider Exco in large firms)

Heads of key business area

Individuals in Group Companies

Control or conduct focused functions

Individuals who supervise or manage

another Certified Person

Significant Harm Functions

/ Material Risk takers (CRR)

Customer-facing roles that are subject to

qualification requirements

Any other SIF roles under the current Approved Persons

Regime

All other employees other than those ancillary staff who perform a role that is not specificto the financial services business of the firm.

Proposed Scope of SMR

SM

FC

R

Con

du

ct R

ule

sFCA REQUIRED FUNCTIONS:

- CUSTOMER SERVICE - CUSTOMER COMPLAINTS HANDLING

GOVERNANCE, CULTURE AND CONTROLS

CONTROLS

CULTURE

GOVERNANCE

‘TONE AT THE TOP’

CORPORATE VISION AND VALUES

COMMUNICATIONS

LEARNING AND DEVELOPMENT (INC. TRAINING)

INCENTIVES

ROLES AND RESPONSIBILITIES

ACCOUNTABILITY

STRUCTURE

OVERSIGHT FORUMS, E.G. TREATING CUSTOMERS FAIRLY (TCF), PRODUCT DESIGN

BUSINESS FILE CHECKING

TRAINING & COMPETENCY (T&C)

CUSTOMER OUTCOMES TESTING

DATA CAPTURE E.G. MI & KEY PERFORMANCE INDICATORS

MYSTERY SHOPPING

PRODUCT GOVERNANCE

MI & BUSINESS REPORTING

COMPLAINTS MI

“DON’T FOCUS ON WHAT YOU CAN COUNT…

32

...FOCUS ON WHAT COUNTS”

WHAT IS “GOOD” COMPLAINTS MI?

% OF CUSTOMERS EXPRESSING

DISSATISFACTION / FCA REPORTING

% OF COMPLAINANTS RECEIVING FAIR

OUTCOMES / FINANCIAL OMBUDSMAN SERVICE

(FOS) OVERTURN RATES

FOCUS ON PRODUCTIVITY AND

QUALITY OPERATIONAL MANAGEMENT

OPERATIONAL EFFECTIVENESS

OVERSIGHT AND CHALLENGE

POSITION AGAINST APPETITE

UNIT TIME / DOUBLE TOUCH / FOS REFERRALS / TRANSACTION FAILURE

RATES

33

Esc

ala

tion

Focu

sed m

anagem

ent a

ction



34


35

2. COMPLAINTS, QUALITY ASSURANCE

AND OUTCOMES TESTING

How to demonstrate you’re delivering fair complaint

outcomes

THE AIM OF QUALITY ASSURANCE (QA)

36

• Identifies “unfair outcomes”

• Demonstrate consistent outcomes

• Assurance regarding the training & competence model

• Key feed of MI into senior management

MAKING QA OUTCOMES FOCUSEDFirms should undertake risk-based outcomes testing to assess the quality of customer outcomes at each stage of the ‘customer journey’

WHY?

Provide assurance that complaints are handled fairly and consistently, delivering fair outcomes for customers – truly assess the ‘quality of complaint handling’

HOW?

• risk weighted• QA activity should consider:

o Was the outcome fair for the customer? o Unfair outcomes – what retrospective / remedial action must you take?o Any conduct breaches (SMR firms)o Consider the underlying root cause and take corrective action

37

AN EXAMPLE END-TO-END CUSTOMER JOURNEY

• For each stage of the customer journey, we have a defined a ‘generic’ set of customer outcomes.

These outcomes represent the key stages of a typical complaints lifecycle

• They are aligned to the firm’s conduct risk strategy

• The purpose of outcomes testing is to determine whether the firm has achieved a fair customer

outcome at each stage of the customer journey

38

IDENTIFICATION INVESTIGATION DECISION COMMUNICATION

39

3. VULNERABLE CUSTOMERS AND

COMPLAINTS

CONSUMER VULNERABILITY HAS BECOME A KEY TEST OF CONSCIENCE FOR THE

CITY

40

MARTIN WHEATLEY – FCA CHIEF EXECUTIVE

MANY FIRMS WILL, FOR EXAMPLE, HAVE HIGHLY SPECIALISED TEAMS TO

DEAL WITH ISSUES RELATED TO CONSUMER VULNERABILITY. YET IF

FRONTLINE STAFF DO NOT HAVE THE EXPERTISE, OR CONFIDENCE, TO

HANDLE THOSE CASES EFFECTIVELY, THE CONSUMER EXPERIENCE IS STILL

LIKELY TO BE A FRUSTRATING ONE

41

MARTIN WHEATLEY – FCA CHIEF EXECUTIVE

42

THE SCALE OF VULNERABILITY IN THE UK

Extracts from FCA Occasional paper 8

OCCASIONAL PAPER 8 – IMPACT ON COMPLAINTS

43

• Vulnerability is not an in or an out – it’s a scale

• Vulnerable customers are, by definition, less likely to complain

• Frontline staff, who represent the point of access for customer, is where investment is required

• Objection handling at point of complaint – vulnerable customers are much more likely to be closed down or experience objection handling

• Vulnerable customers are more likely to make poor choices (both at point of sale and complaint)

• When engaging with vulnerable customers, don’t just think of regulation, what about the law?

OCCASIONAL PAPER 8 – IMPACT ON COMPLAINTS

44

• Information asymmetry – increased for vulnerable customers

o historical approach

⁻ disclosure (not sufficient for vulnerable customers)

⁻ tick box / signature – side steps issue

o FCA now opening the debate about how behavioural economics applies to vulnerable customers

• Some personal examples:

o car Finance - fees complaint

o major Bank - package bank account complaint

o life insurer – critical illness waiver of premium complaint

o general banking complaint – customer perception “blacklisting”

QUESTIONS FOR FIRMS TO CONSIDER

45

Do we want to identify where customers have specific needs that aren’t addressed through our standard process?

How do you consider and apply the differences between vulnerable and particularly vulnerable customers?

Do your customers have a specific need, or are they generally at risk of vulnerability?

What adjustments are reasonable to make for vulnerable customers? How empowered are complaint handlers?

How do you take ‘emotion’ out of the decision, but still be empathetic and deliver fair customer outcomes?

How are your telephone based staff trained to understand the points that customers are making?

How do you give space for the customer to reflect?

Do your front line staff currently view vulnerable customers as opportunities for next business day complaints?





QUESTIONS


5 March 2015





THANK YOU


5 March 2015




RESPOND’S ROADMAP & THE FUTUREPlease contact your Account Manager if you would

like to discuss Road-Map content. These slides

cannot be included in a public release.


QUESTIONS

Duane GeorgeDirector, Respond Product Line

[email protected]

Contact me with any questions about this presentation and the future of Respond

mailto:[email protected]


RESPOND DEMONSTRATIONPlease contact your Account Manager of you like to see a

demonstration of Respond features. This can be offered virtually if

you prefer, or on site.


NEXT: THE FCA THEMATIC REVIEW

• Defining a complaint• Recording ALL complaints and the 3 day rule• Reporting changes (internally and to the FCA)• Written responses (new 3 day rule)• March 2016 … Change Management, are the

people around you ready too?




COMPLAINTS HANDING THEMATIC REVIEW & CONSULTATION PAPER

12:00-12:45


ROUND TABLE DISCUSSIONS

• Each table has an Aptean Facilitator to lead and take notes• There are 5 key topics (following this slide)• For each topic you have 5 minutes to share your thoughts• Then 2 minutes to establish the points• There will be a chime between slides as they auto-progress forward• After the 5 topics there will be closed questions for polling• At the end of today’s sessions we will present the initial results• Aptean will author a more in depth set of results post-event• CHATHAM HOUSE RULE APPLIES


1/5 – GROUP DISCUSSION (INTRO)

DEFINING A COMPLAINT

“Any expression of dissatisfaction” is not the FCA’s definition. The FCA turned down a request to change the definition to this.

FCA: “The complaint must allege that the complainant has suffered (or may suffer) financial loss, material distress or

material inconvenience.”


1/5 – GROUP DISCUSSION (5 MINS)


“Any expression of dissatisfaction” is not the FCA’s definition. The FCA turned down a request to change the definition to this.

FCA: “The complaint must allege that the complainant has suffered (or may suffer) financial loss, material distress or

material inconvenience.”


1/5 – WRAP UP (2 MINS)




RECORDING ALL COMPLAINTS AND THE 3 DAY RULE

The FCA proposes giving firms 72 hours instead of 24 hours to handle a complaint informally … but as a result

every complaint becomes reportable.




The FCA proposes giving firms 72 hours instead of 24 hours to handle a complaint informally … but as a result

every complaint becomes reportable.



REPORTING CHANGESINTERNALLY AND TO THE FCA

The FCA plans to benchmark sales vs complaints and to publish 3 day complaints data too.

Internally what also needs to be done differently to fully consider these 3 day complaints?




The FCA plans to benchmark sales vs complaints and to publish 3 day complaints data too.

Internally what also needs to be done differently to fully consider these 3 day complaints?



WRITTEN RESPONSES UNDER THE 3 DAY RULE

Letter – Email – Text

3 day complaints will require a reply using stock text from the FCA (via any of the above) giving brief case

outcomes, an acknowledgement and FOS referral rights.




Letter – Email – Text

3 day complaints will require a reply using stock text from the FCA (via any of the above) giving brief case

outcomes, an acknowledgement and FOS referral rights.



MARCH 2016 … 1 YEAR FROM NOW

Change Management Plan – Are you gearing up for this? Do you have headcount in the right places? Can

the frontline handle 3 day rules (including written replies)? Is Corporate ready for a 2-3x increase in

published complaints data? Have you replied to the FCA’s Consultation Paper?



• TodayMarc

h 2015

• Go-LiveMarc

h 2016



March 2015

Procurement

System Changes

Culture Change

Training

March 2016




Change Management Plan – Are you gearing up for this? Do you have headcount in the right places? Can

the frontline handle 3 day rules (including written replies)? Is Corporate ready for a 2-3x increase in

published complaints data? Have you replied to the FCA’s Consultation Paper?




RESPOND USER GROUP SESSION

13:45-15:15




RESPOND CASE AND ADVANCED AGENTEric Brown, Solutions Consultant


IMPACT OF 3 DAY INFORMAL PROCESS

AHT?

1 & Done

Coach?

Escalation


SUMMARY COMMUNICATION

For First Point of Contact

• Capture process• Simulated Lookup

• Creating the communication• Resolving an escalation• Email output


SUMMARY COMMUNICATION

Advanced Case Agent

• Configurable capabilities• Supports varied working practices• Reduces operational expenditure


QUESTIONS

Eric BrownSolutions Consultant

[email protected]

Contact me with any questions about Respond’s features and functions

mailto:[email protected]




RESULTS FROM GROUP WORK

15:45



• Over report vs risk of under reporting

• Consistency of Capture and management of complaint

• Training of Front Line Staff and others



• “Just Like Starting Again”

• Clarification from FOS re ability to review summary resolution

• Need to capture more information at Front line – poorer customer service?



• Getting Stakeholder buy in

• Case numbers increasing – perhaps over 500 cases

• Publication of cases – not all companies are the same



• Will use channel of customer complaint to reply

• Cost burden of responding via letter

• Clarification on level of personalisation required



• NOT STARTED YET!

• Cost burden – double staff levels to manage

• Are FOS ready?

1 company confidential do not distribute | © 2014 aptean. all rights reserved. aptean’s crm, erp...

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