Careful Complaint Management
I note that my KevBlog entries have taken a nose-dive recently. Perhaps this is simply due to an absence of thought, associated with my advancing years. However, it's more likely to be linked to admin-overload.
No intermediary firm is immune to the occurrence of customer complaints, and neither are we. It is irritating and disappointing to report that our Network is currently handling a total of four complaints submitted via the FOS, in relation to three of our Appointed Representative firms.
We take a very proactive approach in handling complaints, and are therefore in a good position to arrive at an objective verdict on their essential nature, and also on the process which is there to resolve them. Based upon our own experience, I offer the following observations:
- 75% of complaints received are of an 'opportunistic' nature. The client is disgruntled about something and wants someone to take the blame. The IFA is generally regarded as the weakest link in the chain, and therefore becomes the target.
- Such customers are, generally, not interested in the facts. If the formal response does not take the form of abject acquiescence, they simply resubmit their original complaint.
- The FOS does not appear to have a rigorous process in place to identify where this is happening, and will frequently repaper the resubmitted original complaint as if it were a new one, requiring an entirely fresh investigation.
- The entire process can take aeons. Once a complaint is with FOS, there is little or nothing the target intermediary firm can do to move things along and achieve a resolution, until the FOS is good and ready. Whilst this is no doubt a function of the sheer number of complaints, it does not look good on our RMAR reporting when such cases remain unresolved for so long.
- The FOS appears to somewhat arbitrarily hand out additional fixed penalties for "inconvenience and distress", even if the matter has been handled efficiently and proactively by the intermediary.
- By the time the complaint plops through the FOS' letterbox, it is too late to handle the matter efficiently and cost-effectively. At this stage, you are looking at a prolonged and expensive process - so the temptation is to throw the towel in early unless the complainant is looking for ridiculous levels of compensation.
Our advice?
- Recognise that client dissatisfaction does happen - and particularly in the present difficult economic climate. Whilst the whole regulatory framework appears designed to encourage this kind of opportunism, there is something you can do to compensate for it: keep close to your clients.
- Do everything you reasonably can to handle an expression of dissatisfaction before it gets referred to the FOS. Once it arrives there, you have pretty much lost the battle. This means being cooperative, constructive and proactive in your approach - which sometimes means actively ignoring the kinds of disappointment and hurt caused by implied criticism. It is all too easy to become wrapped up in seeking to defend our own integrity and professionalism.
- Treat expressions of dissatisfaction as a useful TCF tool. The fact is, the client is saying something about your service which you may be able to learn from - if nothing more than the conclusion that you don't want to deal with this kind of individual!
NB. 2020 Financial Services' Members should make sure that they are familiar with the updated section on 'Complaint Handling' in the latest version of the Best Practice Platform, and should utilise the online webform for reporting complaints. |
