Complaints Handling: Compliance with DISP

With the FCA’s Statement on firm handling of complaints during coronavirus no longer in force, all firms are now expected, once again, to fully comply with the complaint handling requirements in DISP - in all but exceptional circumstances linked to the pandemic.

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Some of the considerations within the statement will still be worth bearing in mind. It is certainly the case that the pandemic will still impact customers and exacerbate circumstances that can cause vulnerability – and this will clearly have some longer-term impacts on complaint numbers and subject matter, but the Regulator has been clear that in terms of processing, investigating and providing an outcome, it is back to business as usual.

With the return to full compliance with DISP, it is worth reviewing current practice and training to confirm that they are up to date.

One recurring theme throughout the Complaints Sourcebook is the importance of good communication skills in those dealing with complaints, whether in identifying them, gathering information, investigating or conveying the final outcome. Even one of the main non-compliance issues – the failure to record complaints accurately – often comes down to communication skills. Listening to the complainant and asking the right questions to get a good understanding of the issue, or communicating in writing, an accurate classification or summary of the complaint and the main issues is less common than it should be. And this has a knock-on effect throughout the rest of the treatment of complaints – it may lead to incorrect MI data, inaccurate reporting, and a poor understanding of the root cause of the problem, and therefore missed opportunities to correct something that has gone wrong.

Threaded throughout DISP is the requirement to conduct effective Root Cause Analysis (RCA). In practice, this means that good quality complaints data must be kept, so that it can be analysed for potential causes of complaints, and also whether these causes could be affecting other processes or products. Effective RCA means that staff throughout the complaints department must be trained on the consistent identification and categorisation of complaints, and ensure that there is enough summary information for the analyst to get a good idea of the underlying cause. If the data isn’t captured accurately or consistently, then recurring issues could lead to more customers being affected, and further complaints.

Fair treatment in complaints means having the FCA’s requirement to investigate complaints competently, diligently, and impartially, and assess them fairly, consistently and promptly, at the heart of the work the department does. This makes the information the firm has on the complaint especially important. If the complaint has been reported verbally, then the agent taking the complaint must be able to accurately record what went wrong, and why the customer is complaining. Sometimes more information is needed, so agents and complaints handlers must have the skills necessary to be able to ask questions to understand the underlying issue.

Soft skills are an underrated requirement in complaints handling. Covering knowledge, skills and experience in listening, communication and negotiation, soft skills are vitally important if the agent is to be able to handle difficult situations and manage both their own and the complainant’s emotions well enough to be able to understand and record the reason for the complaint.

Being able to accurately and comprehensively communicate a message is also important, whether the message is that the firm understands the customer’s complaint and will take it seriously, or is the final written communication giving the customer the outcome.

Regular, engaging training on identification of complaints and support of customers making a complaint is hard to find during this working from home period. Our game-based learning platform offers an accessible platform that staff can use to update their skills and knowledge during breaks at work, or during the time they’d normally be commuting. The games deliver soft skills training in an interactive way that is difficult to replicate in other ‘normal’ training styles, as well as covering all of the Regulator requirements and other practical aspects of complaint handling.

Our platform offers a single, online hub of over 200 game-based training modules on subjects that range from consumer credit to complaints handling. Learners gain points from correct answers to build their own bank. Game-based learning is addictive and fun – learners actively return again and again, aiding exposure to the most up-to-date rules and practices. Immediate feedback means that inaccurate answers aren’t embedded, and correct knowledge can be built almost immediately.

To trial our game-based learning platform, email: Robert.bell@rbcompliance.co.uk.