Mortgage arrears and responsible lending - overseas bank
Global banking and financial services company improves customer contact and remediation programme for one of its subsidiaries
We were approached by a global banking and financial services company to assist with a customer contact and remediation programme for one of its subsidiaries. The client agreed to conduct a customer contact exercise and redress programme focused on the following areas: lending into retirement (LIR), interest only (IO) mortgages, arrears handling and arrears charges.
This exercise would impact 8,000 customers who had bought first charge residential mortgages between 2006 and 2008. We developed an end-to-end remediation programme with the client.
The firm required a fully outsourced solution as they did not have the IT infrastructure or operational expertise to support a programme of this nature.
This was the first exercise of its kind that was completed in the industry. We completed an exercise to assess LIR issues. This raised some challenging scenarios for our regulatory experts including the building of a framework to investigate and assess cases and determine the principles and methodology for LIR redesign.
We presented a model that provided infrastructure capabilities to meet our client’s requirements.
We developed an IT infrastructure to include call handling, recording of calls, data processing and document imaging abilities. Our regulatory consultants developed a solution that included the design of the operational policy; process and procedures; the introduction of a strategy to work with a third party complaint handling system provider to develop a bespoke platform to capture customer contact; creation of a call centre to handle customer complaints; and the recruitment and management of a team of call operators and complaint handlers.
This development was executed during a pilot exercise. From these responses, a staggered mailing strategy was devised to ensure that customer responses could be managed in a compliant manner. We also managed the team’s workflow to ensure work was completed on time.
The effective set up phase and the closely managed operation helped to ensure this programme was successful. All enquiries were addressed and all complaints investigated thoroughly; the client’s aim was achieved.
The processes and tools that we created and enforced were embedded into the client’s business as usual complaint handling and collections operation with thorough training. This made the transition easier for the client’s employees.
A comprehensive decommissioning exercise was undertaken to ensure the secure and successful transfer of all data back to the client.
We received green audits throughout the programme from the client’s internal audit department. Another key measure of the review was when customers decided to refer their cases to the FOS, it did not overturn any of them.