CONFIDENTIAL Welcome Topics for Discussion Claims Management
Companies (CMCs) FOS Escalations, Overturns and Fees Time Barring
Proactive Mailing Embracing Complaints Insourcing v
Outsourcing
Slide 3
CONFIDENTIAL Claims Management Companies (CMCs) Impact of CMCs
on workload. Proportion of complaints submitted via CMCs. Engaging
with CMCs and managing the relationship with them. New trends in
CMC behaviour are they starting to look beyond PPI? FOS Annual
Report 2012 cases referred by CMCs: PPI 83% Credit Card 10% Current
Accounts 4% Mortgage Endowments 3% 3
Slide 4
CONFIDENTIAL FOS Escalations, Overturns and Fees What is the
industry experience of FOS escalations? FOS data from the top PPI
providers indicate that approximately 7% of complaints are being
referred. Strategies to minimise FOS referrals and overturns. In
April 2013 the FOS standard case fee increases from 500 to 550.
Supplementary fee for PPI cases: 350. Experience of the FOS
charging per policy rather than per case. Consistency and fairness
of FOS decisions. 4
Slide 5
CONFIDENTIAL Time Barring Normally, customers have six years
from a sale to complain or, if later, three years from when they
became aware (or ought to have become aware) that they had cause
for complaint. When a complaint is made outside this limit, the
firm is no longer obliged to consider it and can reject it; the
Financial Ombudsman Service may also dismiss a complaint made
outside these time limits. FSA Guidance Consultation on PPI
Customer Contact Letters Consumer groups are lobbying against
time-barring. The BBA is pushing the FSA to allow time-barring on
PPI complaints What are your views? 5
Slide 6
CONFIDENTIAL AOB? Any other business? 6
Slide 7
CONFIDENTIAL 7 Thank you for attending
Slide 8
CONFIDENTIAL Additional Information CMCs: 40% to 70% of inbound
complaints originating from CMCs. 30% of CMC cases referred to the
FOS. CMCs undertaking aggressive Subject Access Requests (SARs).
Proactive Mailing: 2 or 3 mailings required to provide fair
opportunity to engage. Little interest in Big Bang unless
population is very small. FOS Escalations and Overturns: No data.
Insourcing v outsourcing: Mixed model provides both flexibility and
control. Embracing Complaints: Feedback welcomed as part of wider
customer strategy. RCA exists but capability is limited due to
system constraints and difficulties integrating different business
areas. 8
Slide 9
CONFIDENTIAL Which? CMC Research Which? conducted two relevant
studies in 2012. Survey of 2,000 consumers indicated: 25% unaware
that CMCs take a fee. 51% believed using a CMC would make their
complaint more successful Mystery shopping of 45 CMCs indicated 33%
had serious shortcomings in their processes, including: Success
rates being exaggerated. Discouraging consumers from pursuing
individual complaints. Failing to disclose charges upfront. 9