Business. Empowered.

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COMPLAINTS HANDLING ROUND TABLE

12th February 2013

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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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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%

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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.

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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?

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AOB?

Any other business?

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Thank you for attending

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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.

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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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