Last week, we discussed basic trends identified in the recently published Key Findings: Complaints Management Thematic Review by the FSB.
Today, we share two of the four specific findings contained in this document to enable readers to test their own systems and procedures against the latest thinking of the Regulator.
Specific Findings
1. The effectiveness of systems for complaints management and consolidated record keeping
In order to capture, store, monitor and analyse complaints data, an insurer should have a system with these functionalities as a minimum, but that would also allow the insurer to appropriately categorise complaints and conduct a root cause analysis and/or identify complaints trends. (Going forward, the proposal is that complaints categories should be aligned to TCF outcomes). An insurer should also, regardless of the sophistication of its complaints management systems, be able to demonstrate that it captures and/or consolidates all complaints in an appropriate register. If a consolidated complaint register is not available, it is not possible to conduct a meaningful root cause analysis.
2. Root cause analysis and corrective action.
An insurer should be able to analyse its complaints data in order to determine the main reason(s) for complaints. This will enable the insurer to pro-actively identify trends and take any corrective action that may be required with regards to a product, a process, a specific employee or type of complaint, or in relation to the complaints management process itself.
Without conducting a root cause analysis an insurer cannot effectively respond to complaints related information as the same type of complaints will re-occur without the ability to take preventative steps to address the actual origin/root cause of complaints.
A number of insurers explained that they do carry out root cause analysis, but could provide little or no evidence that they had taken corrective action in relation to identified complaint trends.
At the risk of stating the obvious: there is little sense in keeping detailed records of complaints if the information is not applied to prevent problems from re-occurring, is there?
A review of your current complaints management procedures, and changes to align it with what Treating Customers Fairly requires, will go a long way towards ensuring that you have documentary proof of steps taken to make TCF part of your business culture.
