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Complaints Handling Round Table

12 th February 2013. Complaints Handling Round Table. Welcome. Topics for Discussion Claims Management Companies (CMCs) FOS Escalations, Overturns and Fees Time Barring Proactive Mailing Embracing Complaints Insourcing v Outsourcing.

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Complaints Handling Round Table

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  1. 12th February 2013 Complaints Handling Round Table

  2. Welcome Topics for Discussion • Claims Management Companies (CMCs) • FOS Escalations, Overturns and Fees • Time Barring • Proactive Mailing • Embracing Complaints • Insourcing v Outsourcing

  3. Claims Management Companies (CMCs) • Impact of CMCs on workload. • Proportion of complaints submitted via CMCs. • Engaging with CMCs and managing the relationship with them. • New trends in CMC behaviour – are they starting to look beyond PPI? • FOS Annual Report 2012 – cases referred by CMCs: • PPI 83% • Credit Card 10% • Current Accounts 4% • Mortgage Endowments 3%

  4. FOS Escalations, Overturns and Fees • What is the industry experience of FOS escalations? • FOS data from the top PPI providers indicate that approximately 7% of complaints are being referred. • Strategies to minimise FOS referrals and overturns. • In April 2013 the FOS standard case fee increases from £500 to £550. Supplementary fee for PPI cases: £350. • Experience of the FOS charging per policy rather than per case. • Consistency and fairness of FOS decisions.

  5. Time Barring “Normally, customers have six years from a sale to complain or, if later, three years from when they became aware (or ought to have become aware) that they had cause for complaint. When a complaint is made outside this limit, the firm is no longer obliged to consider it and can reject it; the Financial Ombudsman Service may also dismiss a complaint made outside these time limits.” – FSA Guidance Consultation on PPI Customer Contact Letters • Consumer groups are lobbying against time-barring. • The BBA is pushing the FSA to allow time-barring on PPI complaints • What are your views?

  6. AOB? Any other business?

  7. Thank you for attending

  8. Additional Information • CMCs: • 40% to 70% of inbound complaints originating from CMCs. • 30% of CMC cases referred to the FOS. • CMCs undertaking aggressive Subject Access Requests (SARs). • Proactive Mailing: • 2 or 3 mailings required to provide fair opportunity to engage. • Little interest in Big Bang – unless population is very small. • FOS Escalations and Overturns: • No data. • Insourcing v outsourcing: • Mixed model provides both flexibility and control. • Embracing Complaints: • Feedback welcomed as part of wider customer strategy. • RCA exists but capability is limited due to system constraints and difficulties integrating different business areas.

  9. Which? CMC Research • Which? conducted two relevant studies in 2012. • Survey of 2,000 consumers indicated: • 25% unaware that CMCs take a fee. • 51% believed using a CMC would make their complaint more successful • Mystery shopping of 45 CMCs indicated 33% had serious shortcomings in their processes, including: • Success rates being exaggerated. • Discouraging consumers from pursuing individual complaints. • Failing to disclose charges upfront.

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