CHALLENGE
- During a desk based review the regulator, the then FSA, identified unsuitable advice in respect of pension transfers and pension / investment switches onto our client’s wrap platform.
- As a result of the feedback, our client wished to engage Huntswood as a skilled person to review a sample of initial cases to assess the suitability of advice. We identified high levels of unsuitable advice and client detriment in this sample that needed to be rectified.
ACTION
- We provided a team of experienced investment complaint handlers, quality assurers and managers with appropriate industry recognised qualifications to independently carry out the pilot review within an agreed timescale.
- We were engaged to carry out a significant review of 9,000 potentially impacted cases and calculate and pay redress to customers where appropriate.
- From the regulator’s feedback, our client made significant and ongoing changes to their complaint handling procedures for the review. Our personnel were challenged to implement, test and feedback on the new procedures, whilst still delivering the pilot within desired timescales.
- After the pilot review, our client wanted to implement a significant review. We were asked to provide 120+ FPC qualified (or equivalent), experienced investment complaint handlers; additional G60 qualified investment complaint handlers to deal with high-net-worth customers and inheritance tax planning cases; and support staff, including administrators and management.
- Our management engaged directly with our client building on the existing relationship. This alongside our proven track record allowed our client to be confident in our ability to deliver and review as agreed.
RESULT
- By providing significant resource, we supported the review of the increased volume of work. The existing contractor resource from the pilot review moved into team manager and quality assurance roles to ensure the knowledge gained from the pilot was retained.
- Our client allowed our contractors with training backgrounds to complete new starter training and sign off. This reduced the impact on our client’s own permanent investment training resource, and ensured the review was self-sufficient in terms of expansion.
- We introduced a Quality Manager who undertook responsibility for the quality assurance function and bought extensive knowledge of process improvement. We carried out a review of the end-to-end process which enabled us to provide our client with options for increasing efficiency.
- Our Operations Manager, who was responsible for delivering the review, managed the day to day operation. We provided the procedures and, once these were embedded into the review, they were important in the rolling out process to permanent colleagues in business as usual (BAU) operations.
- We provided our client with process options for their review procedures and developed automated redress calculators that were not only utilised in the review but in their BAU operations.
- As the review came near to completion, our client was able to complement its BAU operation with additional resource who were already competent.
- Our client had the confidence that production and quality targets would be met or exceeded. This ensured the review was delivered on time and that our client met their regulatory commitments following regulator feedback.
- Our client retained the competent contractor resource we had supplied following completion of the review.