Introduction:
Our client, a specialist bank, had received a number of customer complaints over 12 years about the selling of a niche lending product through brokers. The client had investigated these complaints at the time, and dismissed many because they were outside the standard six-year time limit. Following litigation, a court ruled that our client and others in the industry needed to reinvestigate these complaints under the jurisdiction of the Financial Ombudsman Service (FOS).
The volume and complexity of complaints was beyond the capacity of the bank’s in-house complaints-handling team, and so they outsourced this activity to Firstsource.
Challenges:
This was a complicated lending product, sold through brokers, with the claims going back 12 years. Many of the accounts were no longer active, and some of the brokers had gone out of business. The complex circumstances, with many special cases, meant a straightforward, one-size-fits-all approach wouldn’t work. What’s more, the process was under close supervision by the FOS, which had exacting requirements for documentation.
How we made it happen:
Full ownership of complaints handling and remediation
Firstsource managed the entire process covering: review of the letter of claim, customer testimony, broker sales notes; investigation of missing documents and gathering attestations; evaluation of the complaint with any special circumstances; preparation of documentation, and the provisional decision. This was then followed by multiple reviews within Firstsource, the client and eventually the FOS, any redress calculations, and remediation. Firstsource also handled all liaison with the FOS.
Agile, collaborative process
With so many exceptions, missing documentation, other special circumstances and evolving regulatory criteria, an agile approach was key. The Firstsource team met daily and weekly to review progress, issues and new information. There was also very close collaboration with the client, who was regularly on site to support the team.