The document discusses lessons learned from the FCA's Mortgage Arrears Thematic Review. Key points include:
- The review provides an excellent framework for firms to self-diagnose and prepare for FCA authorization processes.
- Both the methodology and findings are applicable to unsecured arrears reviews.
- A continual improvement program is essential to managing conduct risk.
- Culture, skills/knowledge, and governance arrangements were areas identified for improvement.
2. What should we learn from this?
• Methodology of a Thematic Review provides excellent
framework for self diagnostic
• May provide insight into preparation for the FCA
Authorisation process
• Unsecured Arrears Thematic Review scheduled for Q1 2016
• The key findings are equally applicable to Unsecured
• Continual improvement programme is key to managing
conduct risk profile
3. Methodology of previous Thematic Reviews
Information
Request
Case Study
Reviews
On Site
Visit
Follow Up
& Actions
• Structure Charts
• Policies
• Segmentation
• Forbearance Options
• Strategies
• Operational Procedures
• Outsourcing & SLAs
• MI
• Key Documentation
• Audit & Compliance
• Randomised Selection
• Lifecycle Reviews
• Outcome Testing
• Individual Remediation
• Route Cause
• Interviews
• Observation
• Discussion of Cases
• Queries from Info Req
• Personalised findings
• Action Plans
• Industry Findings
4. Mortgage Arrears Thematic – The good news….
https://www.fca.org.uk/static/documents/thematic-reviews/tr14-03.pdf
5. Mortgage Arrears Thematic – And… The “not so good”….
https://www.fca.org.uk/static/documents/thematic-reviews/tr14-03.pdf
“Culture”
“Pro-active”
“Flexibility”
“Vulnerability”
“Skills & Knowledge”
“Governance Arrangements”
“Inflexible Process & Systems”
6. What could go wrong?
Quality Assurance
MI focussed on ÂŁ
Incentive schemes
Commercial
structures
Supplier oversight
Governance
Management
awareness
Recruitment
Skills & Training
Redress &
Remediation
Operational SLAs &
Tgts
Vulnerability
Do you have a clear definition of “detriment” and
how to define a “good outcome”?
Complaints
Management
Policies (&
Exceptions)
7. Diagnostic Tools – you all have what you need!
• FCA publications
• Your front line staff
• Your Compliance & Internal
Audit functions
• Top down – “Systems engineering”
• Bottom up – “e2e risk assessment”
• Potential detriment mapping
(measures / controls)
8. Culture is a bigger word than it looks
• It’s easy to start at the bottom…
• Fixing the burning issues…
• Setting up your QA frameworks…
• But if the culture from the top isn’t right...
What is a “culture” anyway?
• A pattern of shared beliefs, practices, attitudes and conventions
• Integrated behaviours dependent upon capacity for learning and transmitting
knowledge to succeeding generations
• Customary beliefs of a social group, and characteristic features of everyday existence
shared by people
• But if the culture from the top isn’t right…..
Define
it
Teach
it
Live
it
Measure
it
Reward
it
How to
build it
9. The Role of Quality Assurance… And Controls…
What does good look like?
Call opening
Fact finding
Assessing circumstances
Solutions planning
Agreeing next steps
Call closing
10. Continuous Improvement
Self assessment
Line 2 / Line 3
FCA / LSB
Case Reviews
Complaints & QA ActionPlan
Governance
Owners
KPIs
Controls
Performance
Contracts
Communication
Testing
Good conduct management may be a programme or a
senior management role in its own right
11. Stating the obvious – the 5 C’s of Collections
Customer
Affordability
Conduct
Customer
Cost
Commercials
12. Where next? Lots of you are already going there…
Self service budget planners
Interactive SMS / Live Chat / Web Chat
Payment Portals
Transfer of Information
13. Where next? But there’s room to take it further…
• Good tools & good data
• Better view of affordability
• Shorter phone calls
• Easier for customer
• Reduced costs
• More appropriate solutions
• Better outcomes
14. Stating the obvious – the 5 C’s of Collections
Conduct
Customer
Cost
Commercials
Customer
Affordability
Editor's Notes
Systems Engineering is an interdisciplinary approach and means to enable the realization of successful systems. It focuses on defining customer needs and required functionality early in the development cycle, documenting requirements, then proceeding with design synthesis and system validation while considering the complete problem