Remediating The Past
Helping a fast-growing insurance company to rectify past mistakes and address serious shortcomings in compliance, leaving them fully prepared and self-sufficient for the future.
Challenge:
Strongly focused on rapid business expansion, the insurance company in question had failed to embed a robust culture of compliance and fair treatment for customers. The company’s senior management were insufficiently engaged with compliance matters, incentivising sales volume over quality and handling of complaints.
An inspection by the Financial Conduct Authority (FCA) uncovered serious, systematic and long-running failures across key areas of the business. Our Principal Consultant and team were brought in during the FCA inspection to start immediate implementation of new frameworks to help the client to meet regulatory requirements whilst at the same time balancing the need to acquire, retain and cross-sell to customers.
Solution:
As a result of the FCA inspection and concerns about historic selling practices, the client needed to undertake an exercise to re-contact around 750,000 customers and review the associated sales transactions. This involved segmenting the customer base and developing a mail campaign for ‘at risk’ customers, inviting them to contact a dedicated call centre.
The team recruited, trained, coached and supervised a team of 120 remediation officers, made up predominantly of the client’s internal staff whose original roles had been made redundant as part of a strategic review triggered by regulatory action. The remediation officers connected with all potentially-impacted customers to conduct an assessment of each one’s individual circumstances.
Given that the client had never before undertaken any remediation activities internally, a robust framework was needed to ensure full adherence to expected regulatory standards. The team built a bespoke control framework that included structured quality assurance / quality check and supervisory controls.
The supervisory element incorporated first, second and third line supervisors to underpin the call centre operation, with a Customer Suitability Assessment tool deployed to enable case-by-case assessments within defined parameters. A structured outbound mail programme, personalised to individual customers in line with their circumstances, was developed. The campaign was regulatory-approved and ensured that all customers were contacted within agreed timescales with clear and targeted messaging.
Outcome:
As a result of remediation interventions, the client was left with a fully-trained, fully-compliant, highly motivated and self-sufficient internal remediation capability, an asset which had not previously existed. This enabled the client to conduct further reviews into past business and remediate where necessary. Doing this in-house meant significant cost savings on external fees and demonstrated to the FCA the client’s commitment to rectify past mistakes and improve for the future.
The solution delivered (on time and under budget) gained very positive feedback, both from the client and from the FCA.
