• Our client; a large building society, sought an external supplier with the skills and experience to review and benchmark their complaints framework.
  • Our engagement had been driven by the findings from a recent supervision review conducted by the FCA and the need for the responsible executive for complaints to provide an attestation to the regulator in relation to systems and controls within the department.
  • The firm needed us to review eight areas of ‘best practice’ including governance; management information; staff responsibilities; capacity management; internal complaints procedure; training and competence scheme; root cause analysis; and the use of systems.
  • We were also asked to provide a report outlining findings and recommendations.


  • We created a bespoke test schedule to review and assess the delivery of consistent and fair customer outcomes across the function. This focused on the eight areas of “best practice” that were core to the client.
  • This involved carrying out a detailed assessment of the existing framework, policies and procedures.
  • Following this, we sought to determine the effectiveness of the current framework by benchmarking against regulatory expectations and industry best practice.
  • At the end of this initial phase we delivered a regulatory assurance report that set out our key findings and recommendations.
  • Following this the client invited us to support in the development and build of the future operating environment aligned to the recommendations we had identified. In particular we:
    • Defined the customer complaint outcomes for the firm
    • Built a new complaints framework supported by the eight underlying ‘control’ pillars
    • Designed and built a new QA framework that measured customer outcomes rather than process
    • Rolled out a comprehensive training programme of new framework and carried out accreditation of the QA community
    • Helped the firm respond positively to the FCA’s RMP. This was initially the key driver for this project


  • In our report we recommended that the firm consider enhancing its approach to root cause analysis to ensure that it was able to take appropriate and proportionate activity to address poor complaint handling standards and potential customer detriment.
  • Our findings and recommendations highlighted, based on a benchmarking exercise of the firm’s main competitors, that it was an outlier and offered an inconsistent and poor complaints experience.
  • Following the report, we were engaged to deliver training to frontline quality assurance staff that was aligned to a customer outcomes focused approach instead of one that was process driven. We upskilled the team to enable them to apply judgement and took them through an accreditation scheme to ensure that they were signed off as competent to carry out the new approach.
  • We worked with the firm so that the assessment process used real life customer complaints. This helped ensure quick transference of learning to the operational areas.
  • We provided assurance and an independent view to the responsible executive for complaints so that they were able to make the required attestation to the FCA.