FCA Compliant Complaints Handling

Part One

Session 1: Complaints – what are we talking about in a regulated sense

• What do we understand a complaint to be?
• The FCA definition and how firms have extended it
• Finding the value in complaints
• The regulator’s view on complaints?
• Current FCA focus on complaints and links to the Consumer Duty
• Connected regulation – SYSC, TCF and evidencing our compliance

Session 2: The regulatory environment

• The FCA complaint handling rules – key changes and requirements
• What the regulator is telling us about their findings – an assessment of the FCA Thematic Review
• Examples of good and poor practice as identified by the regulator
• The Summary Resolution – its use and implications
• How do regulated firms set themselves up to both comply with the FCA rules and deliver value to the client
• What the FCA expects of firms
• Case Study: reviewing a complaint received regarding communication to a deceased relative.  Discussion on how we should manage this.

Session 3: Building an effective complaint handling environment

• What does the FCA want from a firm’s framework?
• The roles and expectations of Senior Management Functions
• Procedures – clarity, practicality, transparency
• Effective processes for recording and handling complaints
• The need to understand the underlying cause
• Linking complaints with financial promotions and product oversight & governance
• Systems which deliver consistent, appropriate outcomes in terms of redress
• Should we split regulated and unregulated complaints – advantages and disadvantages
• Should we encourage the front line to escalate all complaints
• What good looks like and how do we often get it wrong?
• Putting ourselves in the customer’s shoes
• How do we gather and record complaint handling information – are systems fit for purpose?
• Case Study – Examples of where frameworks might help or hinder achieving the right client outcome

Part Two

Session 4: Handling Complaints via Telephone and other social technology

• How do we handle telephone complaints – the good, the bad and the ugly
• The structure and environment for an effective complaint handling team
• Dealing with the complaint:
  • Starting well – thanking the client for helping you to understand where you fell short of expectation.
  • Be clear that they have your attention and you want to help
  • The need to gather information
  • How we speak and how we behave
  • Gaining agreement to the root cause of the complaint.
  • Knowing where you want to get to – being flexible on how you get there.
  • The value in letting the client get everything off their chest
  • Mirroring positively
• Directing the conversation naturally
• Signposting for the client so they know “what happens next”

Session 5: “The Angriest caller ever…”

• Understanding the impact on ourselves
• How we should respond vs. how we want to respond
• Consideration will be given to:
  • Few are comfortable with conflict
  • Understanding the need to vent
  • Anger can be useful – it shouldn’t be taken personally
  • Taking the heat out of the complaint
• Earning the customer’s respect and helping them to understand

Session 6: Skilling ourselves to select the most appropriate response

• How to respond when we are at fault
• What skills do we need and how can firms develop them in staff?
• Factors affecting our decision to hold our ground or find with the client
• Succinct responses – referencing without repeating the complaint
• Delivering the message –with empathy, regardless of the outcome
• Case studies:  What are your “go-to” phrases to help arrive at the right outcome tactfully?  Group discussion on responses that participants would be happy to use and the need to make them work in your own voice

Session 7: Winning back the client

• Client involvement in agreeing to a remedy
• Explaining the options to a client – how might we proceed
• Is there a need to inform or educate the client on why things have happened?
• Thinking about future needs (avoiding “I’ve already complained once…!”)

Session 8: The Financial Ombudsman Service

• What does the FOS do?
• What are their powers/duties/obligations?
• What is the process when a complaint goes to the FOS?
• Compensation and Redress
• Case study: Looking at recent FOS decisions to understand their thinking; and how it should influence ours.

Course Wrap-up:

• Summary
• Questions
• Open forum