A practical guide to complaints handling
AMI Yearbook 2011 / 2012 article by Jane Hodges, Chief Operating Officer at TCC: A practical guide to complaints handling
‘The practical guide to complaint handling’…the first thing that most people misunderstand when it comes to complaint handling is the attitude to adopt when that nasty letter appears on your doorstep. The initial reaction is to be angry and upset…how could they possibly have complained?…..and the next natural reaction is to spend a lot of time immediately thinking about all the reasons why the customer is wrong- how could they have misunderstood? I told them that? They just have a poor memory- don’t they?
Now, you have some regulatory obligations on how you must process the complaint- you can find all of this in the FSA website- so I am going to talk more about the things you can’t find in a policy manual.
The first thing is that this is your business and these are your customers. If you start with the view that any complaint is great feedback and you deal with it fairly and in a timely manner- you have every opportunity to win back that customer and even have a stronger relationship then you are in the best place to start with….but this does mean recognising that sometimes you may have made a mistake or a misunderstanding has occurred and be prepared to redress them if that is appropriate.
So look at the complaint very rationally. Who has made it, what is their experience of financial service products, how simple or complex was the advice they were given, was the advice suitable given their circumstances. You will recognise that as an industry we learn things every day, we introduce new products all the time, we sometimes get swept up in the next new and clever product that comes along. Unfortunately we sometimes forget that our customers aren’t as sophisticated in their requirements or as industry savvy as we are.
Over the years you have probably had to learn and apply a lot of rules and regulations and spent a lot of time having files checked to make sure the file is comprehensive. All the rules can be found in ICOB/MCOB or COB if you are hybrid adviser. Even if these are all perfect, it shouldn’t necessarily mean it is fair to reject the complaint and this is where a sense of good judgement comes into play.
If you deal with the complaint and it subsequently goes to the Financial Ombudsman Service (FOS), their first port of call will not be whether the documentation supports the advice. They will look at whether the advice looks suitable for the customers’ circumstances and if that doesn’t feel right they will use the supporting documentation to support this argument or to see if it was clear why this apparent mismatch is actually reasonable and understandable to the customer. Given that they have just complained, the starting position must often be that they obviously didn’t.
You have now fairly and impartially looked at the complaint, assessed whether redress is the right course of action or whether you are going to reject the complaint. You still want to keep that customer if you can, so without compromising your regulatory requirements, you can still deal with it in the right way- even just the right apology- and they could stay with you.
Treating Customers Fairly (TCF) suggests that we should all use complaints to learn lessons and identify root causes of complaints. Is there something that needs to change in your advice process? Are you targeting the right types of customers for your product range? Does anyone need more training in particular areas? Are any other customers potentially affected? Do you need to look at any other cases?
This is why complaints can be so useful and a real eye-opener. They can add to the quality of your business and really show how you are proactively looking after your customers and can get you a reputation for fairness and customer service.
AMI Yearbook 2011 / 2012
