Last week, Industry Events Online held its first webinar, tackling the importance of training in financial services. I think it’s fair to say that it was a success.
To accompany the webinar is a White Paper entitled “Responding to the Threats”, which looks at the issue of training and how it’s taken into consideration by regulators when considering enforcement action.
And talk about timing! As we were putting the finishing touches to the webinar, the FCA published the results of its latest thematic review, this time looking at the subject of complaint handling in major firms.
There have been reviews carried out on this subject before, back in the days of the FSA. But this one was different. The approach was more collaborative. This time, the FCA worked with 15 major firms, the Financial Ombudsman Service and consumer groups to form a working group which would assess the outcomes of the review.
Also, to collect the information, the FCA asked the firms in question to carry out self-assessments, using theoretical customer scenarios to be tested through their existing complaint procedures.
Breaking down barriers
The overriding reason why the FCA carried out this thematic review was to establish whether firms were still putting up barriers to customers wishing to make complaints. The other reason was to test to what extent firms’ procedures drove the right outcomes for customers from the complaint process, as opposed to just technical compliance.
So, this was not a test of firms’ ability to tick the boxes. Far from it. In fact the FCA said this shouldn’t be the case. The complaint handling rules are sufficiently broad that actually, the boxes in question are too big to fill with a tick.
So, if that’s the case, how do firms prove that they are handling complaints effectively? The answer is by demonstrating that customers come away from the complaint process feeling that they’ve been treated fairly.
This requires complaint handlers who can think with that mindset, as opposed to just rigidly following a written procedure.
In other words, it requires staff who are able to exercise a necessary degree of judgement, understanding and empathy with the customer’s position whilst at the same time understanding the regulatory requirements, and the firm’s processes.
And you don’t achieve any of that without having staff who are properly trained.
When you read the White Paper, you’ll discover to what extent the FCA has mentioned training when talking about actions taken against firms. And no sooner is the White Paper published when the FCA does it again.
In the results of the thematic review, there are numerous mentions of training and its importance.
Firstly, the importance of having significant staff training programmes is mentioned in the context of making sure complaints are properly identified and recorded.
Secondly, training is mentioned as an example of good practice, in terms of explaining to staff how to assess and determine distress and inconvenience payments.
Thirdly, examples are provided of how particular firms increased the professionalism of their staff through independently recognised training schemes. In one case, the firm in question worked with an independent qualification body to pilot a training scheme eventually leading to staff obtaining a certificate in complaint handling. In another case, a firm sought independent verification from a professional institution about the standard of its training programme.
Finally, the FCA makes reference to, in one instance, how training made the difference in staff being able to understand how to distinguish between distress and inconvenience payments and gestures of goodwill.
No training for training’s sake
What’s clear here is that the FCA is expecting firms to think carefully about how they set out their training programmes, as opposed to just rolling out a general programme and saying that staff have been trained.
Of course, there will always be a need for fundamental training programmes for new starters and those transferring into complaint-handling roles.
But above and beyond that, what the FCA is looking for is: can a firm’s complaint-handling staff apply the appropriate level of judgement, discretion and professional skill to ensure that each customer complaint is handled in a way that delivers the right outcome?
If not, where are the gaps or deficiencies, both in terms of processes and individual skill levels?
Having identified these, what are the most appropriate areas to train staff in, and what are the most effective methods of doing this?
The examples given by the FCA serve to demonstrate that there are a number of ways in which training can be approached these days; and that firms are expected to tailor their approach to their specific requirements.
And it’s exactly this kind of situation where Industry Events Online is perfectly placed to provide support.
All the resources are there to help to construct training programmes for complaint-handling teams. Not just in terms of events and qualifications, but simply the ever increasing number of training providers, professional bodies and academic institutions – all of whom provide a valuable source of contacts, especially if your need is for something a little more bespoke.
The issue of how best to construct training programmes is also tackled in the White Paper. Getting hold of a copy is easy - just email firstname.lastname@example.org.
One last thought
Although the review encompassed only 15 major firms, the FCA has made it clear that all firms are expected to consider the themes brought out in the paper, and consider where they may need to make improvements.
And if training is one of these areas, you can start here.
By Martyn Oughton a Professional Member of the International Compliance Association (ICA). Martyn now writes a regular blog for Industry Events Online focusing on the importance of training in all aspects of compliance. Read Martyn's other publications at Martyn's Writers' Residence website.
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